## Facts

- Jesse Skinner killed his wife by strangulation while on a day pass from Camarillo State Hospital.
- Skinner had a long history of serious mental illness; an expert diagnosed paranoid schizophrenia or schizoaffective disorder.
- Evidence showed Skinner understood the physical nature of his act (he knew he was strangling his wife).
- Skinner believed, because of a delusional religious view of marital vows, that he had a divinely sanctioned right or duty to kill his wife if she violated those vows.
- In the sanity phase, the trial court treated Penal Code § 25(b) as requiring proof that Skinner both (1) could not understand the nature and quality of his act and (2) could not distinguish right from wrong, and found him sane because he understood what he was doing.

## Issues

1. Whether Penal Code § 25(b) requires a defendant to prove both inability to understand the nature and quality of the act and inability to distinguish right from wrong, or whether those are alternative (disjunctive) bases for insanity.
2. Whether “distinguishing right from wrong” in § 25(b) refers only to legal wrongfulness or also includes moral wrongfulness.
3. Whether, under the correctly construed standard, Skinner was legally insane at the time of the offense.

## Decision

- The California Supreme Court reversed.
- The court held § 25(b) reinstated the pre-Drew M’Naghten test and must be applied disjunctively: insanity is established if the defendant proves either inability to understand the nature and quality of the act or inability to distinguish right from wrong.
- The court held the right/wrong inquiry includes moral wrongfulness, not merely knowledge that the act is illegal.
- Applying that standard, the court concluded the evidence compelled a finding that Skinner was incapable of distinguishing right from wrong because his psychotic delusion made him believe the killing was morally justified and divinely sanctioned.
- The court directed entry of a judgment of not guilty by reason of insanity.

## Legal Principles

- Penal Code § 25(b) restores California’s traditional M’Naghten insanity test and rejects the former ALI-based standard.
- The two M’Naghten prongs operate independently; proof of either prong satisfies the insanity defense.
- “Wrong” in the M’Naghten right/wrong prong includes moral wrongfulness as well as legal wrongfulness.
- A defendant who knows an act is unlawful may still satisfy the right/wrong prong if, because of mental disease, the defendant sincerely believes the act is morally right or commanded by God.

## Conclusion

The court construed Penal Code § 25(b) to reinstate the disjunctive M’Naghten insanity test and to treat “wrong” as moral as well as legal, then held Skinner legally insane because his psychosis prevented him from recognizing the moral wrongfulness of killing his wife.


People v. Skinner, 39 Cal. 3d 765 (Cal. 1985)