DANIEL M’NAGHTEN’S CASE

Daniel M’Naghten’s Case, 8 Eng. Rep. 718, 10 Cl.&Fin. 200 (1843)

BY: James F. Polk – AISOL YEAR ONE STUDENT

History:  Defendant M’Naughten was charged with Murder and also acquitted of the same by reason of insanity.

Facts:  M’Naughten pointed a pistol at the back of Edward Drummond and shot him.  Drummond died in April of that year after first having been shot in January of that year.  M’Naughten believed Drummond was part of a conspiracy to kill him.

Issue:  Was the Jury given the proper instructions with respect to the definition of insanity and when to acquit?

Reasoning:  It must be proved that at the time of acting, the Defendant was acting guided by a defect of reason from a disease of the mind such that he could not distinguish the nature and quality of the act committed for there to be an Insanity Defense.  If the Defendant did in fact know the nature and quality of the act, the Defendant cannot know of the wrongfulness of the act.

Analysis:  The key question was whether or not the Defendant knew what he did was illegal.  In this case the Defendant thought he was defending himself and could not be found Guilty because he did not know the nature of his actions.

Conclusion:  Not Guilty by way of Insanity verdict upheld.  Yes the Jury was properly instructed.

M’Naughten Rule: (from findlaw) “The M’Naghten Rule (or test) was established by the English House of Lords in the mid-19th Century and states that:

“Every man is to be presumed to be sane, and … that to establish a defense on the ground of insanity, it must be clearly proved that, at the time of the committing of the act, the party accused was laboring under such a defect of reason, from disease of mind, and not to know the nature and quality of the act he was doing; or if he did know it, that he did not know he was doing what was wrong.”” – (/findlaw)