## Facts

- Nancy J. Parsons and her daughter, Joe Parsons, were indicted in the City Court of Birmingham for the murder of Nancy’s husband, Bennett Parsons, alleged to have been committed by shooting him with a gun.
- The State’s evidence tended to show that Nancy and Joe participated in killing Bennett on January 31, 1885 by shooting him.
- The defense evidence tended to show that Joe Parsons was an “idiot,” and had always been so.
- The defense evidence also tended to show that Nancy Parsons was insane at the time of the killing and acted under an insane delusion that Bennett had supernatural power to make her ill and to take her life by a “supernatural trick,” and that she believed she was in serious danger of death from him.
- The defendants were tried and convicted. Nancy’s counsel appealed to the Alabama Supreme Court.
- On appeal, the defendants challenged (1) the service and sufficiency of the special venire list for the jury, and (2) the trial court’s treatment of the insanity defense in its jury instructions, including whether the law should recognize loss of self-control caused by mental disease even when the defendant knows the act is wrong.

## Issues

1. Whether the trial court committed reversible error by requiring the defendants to proceed to trial when the served list of special jurors included persons who had not yet been summoned and some of whom were later returned “not found.”
2. Whether Alabama’s insanity defense is limited to the M’Naghten knowledge-of-right-and-wrong test, or also excuses a defendant who, because of mental disease, lacks the power to choose between right and wrong and to avoid the act.
3. Whether, under any loss-of-control rule, the defendant must show the criminal act was caused by the mental disease and was the product of that disease alone.

## Decision

- The court found no reversible error in the manner the jury list/statutory venire requirements were handled, concluding the statutory requirements were substantially satisfied and no prejudice requiring reversal was shown.
- The court rejected a purely cognition-only insanity standard as insufficient for all cases of mental disease.
- The court announced that Alabama’s insanity doctrine has two routes to non-responsibility: (1) lack of knowledge of the act’s nature/quality or its wrongfulness, or (2) loss of the power to choose and to avoid the act because mental disease destroyed free agency, provided the act was caused by, and solely the product of, the disease.
- Because the jury was not properly instructed to consider this fuller insanity rule in light of the evidence of delusions and claimed compulsion, the judgment was reversed and the cause remanded for further proceedings under the correct legal standard.

## Legal Principles

- Insanity may excuse criminal liability when mental disease prevents the defendant from knowing the nature and quality of the act, or from knowing the act is wrong.
- Even if the defendant knows the act is wrong, insanity may also excuse liability when mental disease destroys the defendant’s power to choose between right and wrong and to avoid doing the act, such that the defendant’s free agency is destroyed at the time of the offense.
- The loss-of-control component is limited: the act must be connected to the mental disease as cause and effect, and must be the product of the disease alone, not merely the result of anger, passion, moral depravity, or an ordinary impulse.
- A defendant’s delusions may be legally significant when they result from mental disease; if such delusions drive the defendant in a way that meets the knowledge or loss-of-control criteria, the defendant may be found not responsible.
- Trial courts must instruct juries on the full insanity standard supported by the evidence; limiting the jury to a cognition-only test can be error when the proof raises a disease-based inability to control conduct.

## Conclusion

Parsons v. State held that Alabama’s insanity defense is not confined to whether the accused intellectually knew the act was wrong; it also applies when mental disease destroys the ability to choose and to refrain from the act, so long as the crime was caused by and solely the product of that disease. Although the court did not reverse on the jury-venire objection, it reversed and remanded because the jury instructions did not adequately present this broader insanity rule to the jury in a case involving evidence of idiocy and delusion-driven conduct.


Parsons v. State, 81 Ala.577, 2 So. 854 (1887)