## Facts

- After the defendant, Crenshaw, was deported from Canada following a fight during his honeymoon, he waited in Washington at a hotel for his wife to arrive.
- When his wife arrived two days later, Crenshaw concluded she had been unfaithful and beat her unconscious in the hotel room.
- Crenshaw went to a nearby store, stole a knife, returned to the hotel, and stabbed his wife 24 times.
- He then decapitated her with an ax he borrowed from a farm where he had worked.
- Crenshaw cleaned blood from the hotel room and transported the body to a remote location about 25 miles away for disposal.
- He fled and later picked up two hitchhikers, told them what he had done, and asked for help disposing of his wife’s car in a river.
- The hitchhikers contacted police; Crenshaw was apprehended soon after and confessed.
- At trial, Crenshaw asserted an insanity defense, testifying that he followed the “Moscovite” religious faith, which (as he understood it) required him to kill his wife if she committed adultery.
- Evidence also showed a history of mental illness and hospitalization.
- The jury found Crenshaw guilty of first-degree murder, and he appealed, challenging how the jury was instructed on insanity—especially what “wrongfulness” means when a defendant claims a delusion or belief that the act was morally required.

## Issues

1. Under Washington’s insanity standard, is “wrongfulness” measured by the defendant’s personal moral beliefs (including a claimed religious duty to kill) or by generally accepted societal standards?
2. Did the trial court err by refusing to instruct the jury that a defendant is insane if, because of mental disease or defect, he believed the killing was morally right even if he knew it was illegal?

## Decision

- The Washington Supreme Court affirmed Crenshaw’s first-degree murder conviction.
- The court held that “wrongfulness” in Washington’s M’Naghten-based insanity test is not determined by a defendant’s personal moral code or idiosyncratic religious belief.
- The court approved an objective approach: “wrong” refers to acts that are contrary to societal standards of morality (and not merely contrary to the defendant’s private sense of right), and knowledge that the act is legally forbidden is strong evidence the defendant understood its wrongfulness.
- Because the proposed instruction would have directed the jury to apply Crenshaw’s own moral beliefs—rather than society’s—the trial court properly refused it.

## Legal Principles

- Washington applies an M’Naghten-type insanity test: a defendant is legally insane only if, at the time of the act, mental disease or defect made him unable to perceive the nature and quality of the act, or unable to tell right from wrong.
- “Wrong” (or “wrongfulness”) is judged by generally accepted societal standards, not by a defendant’s personal, religious, or self-defined moral rules.
- A claim that one’s religion required or justified the killing does not by itself establish legal insanity; the question remains whether the defendant lacked the capacity required by the insanity standard.
- Evidence that a defendant attempted to conceal the crime or avoid detection can support a finding that he understood the act was wrong by society’s standards.

## Conclusion

The Washington Supreme Court upheld Crenshaw’s conviction, concluding that Washington’s insanity defense does not turn on whether the defendant believed his act was morally justified under his own religious code; instead, “wrongfulness” is evaluated against society’s moral standards (with illegality strongly indicating wrongfulness), and the jury instructions were proper under that rule.


State v. Crenshaw, 98 Wash. 2d 789 (1983)