## Facts

- Don Anthony White was charged by information with two homicides committed on December 24, 1959, at different times and locations in Seattle.
- Count I alleged first-degree murder of Alice Jumper, committed with premeditation and during rape and robbery; she died the next day from her injuries.
- Count II alleged second-degree murder of Willie LeRoy Dixson, whom White assaulted later the same day.
- The State introduced three signed written statements by White describing his conduct during the relevant period, including the assaults and his consumption of alcohol and marijuana.
- White pleaded not guilty and also pleaded not guilty by reason of mental irresponsibility (insanity).
- A jury found White guilty on both counts and returned a special verdict imposing the death penalty on Count I.

## Issues

1. Whether the trial court erred by instructing the jury under Washington’s M’Naghten-based insanity test and refusing an “irresistible impulse” (volitional incapacity) instruction.
2. Whether White’s signed statements were involuntary and therefore inadmissible due to his alleged intoxication and mental condition, and whether the jury was properly instructed on their consideration.
3. Whether other challenged evidentiary rulings, instructions, and matters relating to the death-penalty special verdict required reversal.

## Decision

- The Washington Supreme Court affirmed the convictions and the death sentence.
- The court held that Washington’s criminal-insanity standard remained the M’Naghten rule and that the trial court properly refused an irresistible-impulse instruction.
- The court held that the trial judge properly admitted the signed statements after determining voluntariness; mental condition and intoxication affected weight, not admissibility on this record.
- The court rejected the remaining assignments of error as nonprejudicial.

## Legal Principles

- Washington’s test for criminal insanity is the M’Naghten rule: a defendant is not criminally responsible only if, due to mental disease, the defendant did not know the nature and quality of the act, or did not know the act was wrong.
- A defendant’s asserted inability to control conduct, despite knowledge of wrongfulness, is not a basis for acquittal by reason of insanity under Washington law absent adoption of a different standard.
- Voluntariness of a confession is a preliminary question for the trial judge; once admitted, the jury may consider evidence of intoxication or mental condition in determining the statement’s credibility and weight.
- Intoxication or mental impairment does not automatically render a confession inadmissible; exclusion requires a showing that the statement was not voluntary under the circumstances.

## Conclusion

The court upheld White’s murder convictions and capital sentence, concluding that the jury was correctly instructed under the M’Naghten insanity rule and that White’s confessions were voluntarily made and properly admitted, with other alleged trial errors providing no ground for reversal.


State v. White, 60 Wash. 2d 551, 374 P.2d 942 (Wash. 1962)