New York
How Durham v. United States applies in New York: state-specific rules, key cases, and bar exam notes for Criminal Law.
New York does not fully adopt the 'Durham Rule', which allowed for a broader understanding of insanity based on the 'product test'. Instead, New York follows the M’Naghten Rule, focusing on whether a defendant could understand the nature of their actions or distinguish right from wrong. Thus, only similarities in use of psychiatric evidence persist.
In New York, the insanity defense is governed by the M’Naghten Rule, where a defendant is not criminally responsible if, due to a mental disease or defect, they lacked substantial capacity to appreciate the nature of their conduct or to understand that it was wrong.
The court affirmed the use of a strict M’Naghten standard and rejected broader interpretations of mental illness like those in Durham.
The court reiterated the necessity of proving a cognitive inability to understand the wrongfulness of the act under the M’Naghten test.
The defendant was found not guilty by reason of insanity under the M’Naghten Rule after expert testimony established a severe mental disorder.
While federal law permits an insanity defense under a more forgiving standard, New York enforces a stricter M’Naghten Rule that aligns closely with traditional tests of criminal responsibility. This results in a narrower scope for the insanity defense in New York compared to some federal applications, such as the ALI's Model Penal Code standard.
Understanding the M’Naghten Rule and how it differs from the Durham Rule is crucial for the New York bar exam, especially in criminal law questions addressing mental disease defenses.