## Facts

- Terry Lee Staten was indicted for first-degree murder in Ohio and entered a plea of not guilty by reason of insanity.
- Staten was tried in the Court of Common Pleas before a three-judge panel (bench trial) and introduced evidence of mental disease or defect.
- The panel convicted Staten of first-degree murder without a recommendation of mercy (a capital consequence at the time).
- During trial, a judge stated that the M’Naghten rule governed criminal insanity in Ohio, but the record did not clearly show what standard the panel applied in deciding the insanity defense.
- On appeal, Staten argued for an insanity standard based on mental disease or defect causing lack of substantial capacity to appreciate wrongfulness or to conform conduct to law.

## Issues

1. What legal test governs criminal responsibility when insanity is raised in Ohio: a strict M’Naghten right-and-wrong test or a broader standard including inability to conform conduct to law?
2. Whether Staten’s conviction could stand when the record did not permit determination that the trier of fact applied the correct insanity test.

## Decision

- The Supreme Court of Ohio announced a dual-prong test for criminal insanity: a defendant is not responsible if, due to mental disease or defect, the defendant lacked capacity either to know the wrongfulness of the conduct or to conform conduct to the requirements of law.
- The court reversed the judgment affirming Staten’s conviction because it could not determine from the record what insanity test the three-judge panel used.
- The case was remanded to the trial court with instructions for the same panel to adhere to its prior judgment only if it had applied, or would reach the same result under, the proper insanity standard; otherwise, the panel was to enter the judgment it would have rendered under that standard.

## Legal Principles

- A defendant is not criminally responsible if, at the time of the act, as a result of mental disease or defect, the defendant lacked capacity either (1) to know the wrongfulness of the conduct, or (2) to conform the conduct to the requirements of law.
- The insanity inquiry includes both a cognitive component (knowledge of wrongfulness) and a volitional component (capacity for control), and lack of either capacity may establish the defense.
- When insanity is raised, the defendant is presumed sane and bears the burden to prove insanity by a preponderance of the evidence.
- Where the record does not disclose whether the trier of fact applied the correct insanity standard—especially in a capital case—reversal and remand for reconsideration under the proper rule is required.

## Conclusion

The court broadened Ohio’s insanity standard to include inability to conform conduct to law as an alternative to lack of knowledge of wrongfulness, and it reversed Staten’s conviction because the record did not show that the trier of fact used the correct test in rejecting the insanity defense.


State v. Staten, 247 N.E.2d 293 (Ohio 1969)