Kahler v. Kansas

Whether the Eighth and Fourteenth Amendments permit a state to abolish the insanity defense

After killing his family, Petitioner was convicted of capital murder and sentenced to death. As an affirmative defense, Petitioner produced evidence that he suffered from several forms of mental illness.  At trial, the jury was instructed to consider this evidence only insofar as it showed that Petitioner “lacked the mental state required as an element of the charge.”  The jury found Petitioner held the requisite mental state for murder.  On appeal to the Kansas Supreme Court, Petitioner argued that the evidence of his mental illness should have been considered under the M’Naghten rule, which would allow a jury to find a defendant not criminally responsible “where he does not know the nature and quality of his act.”  The Kansas Supreme Court affirmed Petitioner’s conviction. On appeal to the United States Supreme Court, Petitioner argues that he was entitled to the insanity defense because no criminal responsibility should attach where the accused is incapable of forming a guilty intent. Petitioner argues that the Constitution mandates an insanity defense. He urges the Court to find that Kansas’s mens rea approach violates Eighth Amendment’s prohibition of cruel and unusual punishment and the Fourteenth Amendment’s due process guarantee because capital punishment should be “reserved for people who can distinguish right from wrong.”