## Facts

- Conrad Maas shot and killed his wife, Martha Maas, in Oklahoma Territory.
- Maas was charged with murder in the District Court of Blaine County.
- At trial, Maas asserted insanity, including that he acted under an “insane delusion,” and therefore lacked criminal responsibility.
- The trial court instructed the jury that sanity is presumed; the defendant must first produce evidence raising a reasonable doubt of sanity, after which the prosecution must prove sanity beyond a reasonable doubt.
- The trial court also instructed that a defendant is criminally responsible if he had sufficient mental capacity to know the act was wrong and punishable by law, even if affected by insanity or delusion.
- The jury convicted Maas of murder, and the court sentenced him to life imprisonment at hard labor.
- After conviction, Maas sought arrest of judgment and requested a jury inquiry into his sanity at sentencing; the trial court denied the request.

## Issues

1. Whether the jury instructions on insanity improperly allocated the burden of proof or misstated the legal test for criminal responsibility when the defendant claimed an insane delusion.
2. Whether the trial court was required to empanel a jury to determine Maas’s sanity at the time of sentencing when ruling on his motion in arrest of judgment.

## Decision

- The Oklahoma Supreme Court affirmed the conviction and life sentence.
- The court held the insanity instructions correctly stated that sanity is presumed, the defendant must first raise a reasonable doubt with evidence, and then the prosecution must prove sanity beyond a reasonable doubt to convict.
- The court held the substantive test for insanity under the governing statute was whether the defendant could know the wrongfulness of the act and that it was punishable by law; the presence of mental illness or delusion alone did not excuse criminal liability.
- The court held a sentencing-time sanity jury is required only if the trial judge entertains a reasonable doubt as to the defendant’s sanity at judgment; denial of the motion signified no such doubt, and the record did not clearly require a contrary finding.

## Legal Principles

- A defendant is presumed sane; the defendant bears an initial burden of production to introduce evidence sufficient to raise a reasonable doubt of sanity, after which the prosecution must prove sanity beyond a reasonable doubt.
- Criminal responsibility turns on a cognitive “knowledge of wrongfulness” standard: if the defendant had sufficient mental capacity to know the act was wrong and punishable by law, he is responsible even if affected by insanity or an insane delusion.
- A trial court must empanel a jury to inquire into sanity at the time of sentencing only when the judge has a reasonable doubt about present sanity; the judge’s determination will be reversed only if the record clearly shows evidence sufficient to raise such a doubt.

## Conclusion

The court affirmed Maas’s murder conviction and life sentence, holding that the challenged insanity instructions properly applied a presumption of sanity with a burden-shifting framework and a wrongfulness-based responsibility test, and that no separate sanity jury at sentencing was required absent a reasonable doubt entertained by the trial judge.


Maas v. Territory, 63 P. 960 (Okla. 1900)