## Facts

- The defendant knew the victim, Jack Peters, through Peters’s son, Dirk, whom the defendant had attended high school with.
- The defendant developed persecutory delusions that Dirk and Jack Peters were part of an organization attempting to control his mind and destroy his life.
- The defendant attributed various personal misfortunes to Jack Peters, including job loss, sexual dysfunction, loss of strength, deaths of family members/pets, and relationship problems.
- For months before the killing, the defendant contacted police to report the alleged conspiracy; police indicated there was no basis to investigate.
- On August 5, 1993, the defendant went to Jack Peters’s home to confront him, argued with him, and shot and killed him.
- After the shooting, the defendant surrendered to police and stated he had “no choice” but to shoot the victim.
- At trial for murder, the defendant asserted the affirmative defense of insanity under Conn. Gen. Stat. § 53a-13.
- Expert testimony described the defendant as remorseful but also believing the killing was necessary to save others, that he had “saved the world,” and that he had a higher moral duty to kill the victim.
- The defendant requested a jury instruction defining “wrongfulness” in moral terms, allowing acquittal if mental disease caused him to believe the act was morally justified even if he knew it was illegal.
- The trial court rejected that request and instructed the jury using a more legal-focused conception of wrongfulness; the jury convicted the defendant of murder.

## Issues

1. How should “appreciate the wrongfulness of his conduct” in Conn. Gen. Stat. § 53a-13 be defined for the insanity defense?
2. Does “wrongfulness” refer only to legal wrongfulness (illegality), or does it also include moral wrongfulness assessed against societal standards when the defendant’s mental illness distorts perceived reality?
3. Whether the trial court’s jury instruction misstated the wrongfulness requirement and thereby required reversal.

## Decision

- The Connecticut Supreme Court held that “wrongfulness” under § 53a-13 includes moral as well as legal wrongfulness.
- The Court held a defendant lacks capacity to “appreciate the wrongfulness” of conduct when mental disease or defect causes a distorted perception of reality such that, under the circumstances as the defendant honestly perceives them, the conduct would not offend societal morality, even if the defendant knows the conduct is illegal.
- The Court concluded the jury was not properly instructed on the wrongfulness element of insanity and ordered a new trial.

## Legal Principles

- Under Connecticut’s insanity statute, “wrongfulness” is not limited to knowledge of illegality; it also includes moral wrongfulness.
- “Appreciate” requires more than cognitive awareness that conduct violates the criminal code; it requires meaningful understanding that the act is wrong in light of shared moral norms.
- A moral-wrongfulness inquiry is limited to cases where mental illness distorts the defendant’s perception of reality; it does not excuse conduct based on purely personal moral standards disconnected from reality.
- The relevant moral assessment is whether, given the circumstances as the defendant honestly (though delusionally) perceives them, the conduct would be regarded as morally justified by ordinary societal standards.

## Conclusion

The court interpreted Connecticut’s insanity defense to require consideration of moral wrongfulness in addition to illegality and to focus on whether mental illness distorted the defendant’s perceived reality so that he could not appreciate societal moral condemnation of his act; because the jury charge used an unduly legal conception of wrongfulness, the conviction was reversed and the case remanded for a new trial.


State v. Wilson, 242 Conn. 605, 700 A.2d 633 (Conn. 1997)