Clark v. Arizona, 548 U.S. 735 (2006)
Primary Holding
The Supreme Court held that due process does not prohibit Arizona's use of an insanity test that focuses solely on the defendant's capacity to distinguish right from wrong, nor does it violate due process to restrict the consideration of mental illness evidence to its relevance for an insanity defense, thereby excluding its impact on the mens rea element of the charged crime.
In the case of Clark v. Arizona, a man named Eric Clark was charged with killing a police officer. The Supreme Court decided that Arizona's rules about how to handle mental illness in court were okay, meaning they could focus only on whether Clark knew right from wrong at the time of the crime, rather than considering his mental illness in other ways. This matters for consumers because it sets limits on how mental health issues can be used in criminal cases, which can affect anyone facing similar charges or situations involving mental health and the law.
AI-generated plain-language summary to help you understand this case
Clark killed a police officer during a traffic stop and was prosecuted for first-degree murder. While he admitted to shooting the officer, he claimed that his paranoid schizophrenia negated the specific intent element because he did not know that he was shooting the officer. However, he was prevented by the trial court from introducing psychiatric evidence related to insanity when he was contesting the mental state element. Unless the defendant was insane, according to the trial court, Arizona law did not permit him to use evidence of a mental disorder to challenge that element. Clark was ultimately convicted.
Whether due process prohibits Arizona’s use of an insanity test stated solely in terms of the capacity to tell whether an act charged as a crime was right or wrong, and whether Arizona violates due process in restricting consideration of defense evidence of mental illness and incapacity to its bearing on a claim of insanity, thus eliminating its significance directly on the issue of the mental element of the crime charged (mens rea).
The judgment is affirmed.
A state is free to curtail the types of evidence that a defendant can submit as long as it has legitimate reasons for doing so, but not every state needs to reach the same conclusion on any given issue.
- Court
- Supreme Court
- Decision Date
- April 19, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
Indiana v. Edwards, 554 U.S. 164 (2008)
Consumer LostA state may insist that a criminal defendant, who is found mentally competent to stand trial but not competent to represent himself, proceed with legal counsel, thereby denying the defendant the right to self-representation under the Sixth Amendment.
Schriro v. Smith, 546 U.S. 6 (2005)
Consumer LostThe Ninth Circuit erred in requiring a jury trial to determine Smith's mental retardation claim, as states have the authority to develop their own procedures for adjudicating such claims, and the federal courts should not preemptively impose conditions on state proceedings.
Schriro v. Landrigan, 550 U.S. 465 (2007)
Consumer LostThe decision to grant an evidentiary hearing in federal habeas relief cases rests within the discretion of the district court, and such a hearing is not warranted if the applicant cannot make out a colorable claim of ineffective assistance of counsel.
Oregon v. Guzek, 546 U.S. 517 (2006)
Consumer LostThe State may constitutionally limit the innocence-related evidence that a defendant can introduce at a new sentencing proceeding to only that evidence presented at the original trial.