## Facts

- Gary A. Cameron was charged with premeditated first-degree murder for killing his stepmother, Marie Cameron, and asserted an insanity defense.
- On June 9, 1980, Cameron stabbed the victim more than 70 times, left the knife in her heart, and left the body in a bathtub without concealment.
- Later that day, a police officer encountered Cameron in public wearing unusual clothing and no shoes; Cameron gave a false name, then explained he fled after his “mother-in-law turned vicious,” and said he was headed to California; the officer released him.
- The next day, Oregon police detained Cameron near Interstate 5 because of his appearance and later learned he was wanted for the homicide.
- Cameron gave a taped oral confession and a written confession describing the victim as evil and involved in witchcraft; he said he “just kept stabbing her.”
- Cameron stated he knew the act was illegal but believed it was not wrong “in the eye of God.”
- Multiple psychiatric experts diagnosed paranoid schizophrenia and testified Cameron believed God commanded him to kill the victim; the experts agreed he was legally insane at the time.

## Issues

1. Whether the trial court’s insanity instruction erroneously defined “right and wrong” solely as knowledge the act was “contrary to the law,” thereby preventing the jury from considering moral incapacity evidence, including a claimed divine-command delusion.
2. Whether admitting evidence of foreign pubic hairs found on the victim’s body was reversible error.
3. Whether admitting hearsay about an alleged statement by the victim two months before the killing was reversible error.

## Decision

- The Washington Supreme Court reversed the conviction and the Court of Appeals’ affirmance and remanded for further proceedings.
- The court held the added sentence equating “right and wrong” with knowledge of illegality was erroneous and prejudicial because it restricted the jury’s consideration of the insanity defense.
- The court concluded there was insanity evidence the jury could have credited but for the improper instruction, particularly where the defendant claimed he acted under a perceived divine command.
- The court limited its discussion to issues supporting reversal, with the insanity-instruction error as the principal basis.

## Legal Principles

- Washington’s insanity test asks whether, due to mental disease or defect, the defendant was unable to perceive the nature and quality of the act or unable to know right from wrong.
- “Right and wrong” in the insanity inquiry cannot be confined to awareness that the act is legally prohibited when the evidence supports a delusional belief that a higher authority (e.g., God) required the act.
- An instruction that collapses “right and wrong” into mere legal knowledge can remove from the jury the central question whether mental illness prevented appreciation of moral wrongfulness, and may deny a fair determination of the insanity defense.

## Conclusion

The court reversed and remanded because the jury instruction improperly limited “right and wrong” to legal wrongfulness, preventing full consideration of evidence that Cameron’s schizophrenia and claimed divine-command delusion could have rendered him unable to recognize the moral wrongfulness of the killing.


State v. Cameron, 100 Wash. 2d 520, 674 P.2d 650 (Wash. 1983)