Supreme Court rejects Idaho case on prohibiting the insanity defense

Delling shot his first victim several times, but the man lived. He shot his second and third targets in the head. Both died. Prosecutors said that, at the time of Delling’s arrest, four other names remained on his kill list.

Delling’s lawyers said their client suffered from extensive delusions and believed he was acting in self-defense. They said Delling lacked the ability to form a rational understanding of the wrongfulness of his conduct.

Under those circumstances, they said, he should be permitted to claim the insanity defense.

Prosecutors in Idaho disagreed. They said Delling had been methodical in planning his crimes and, despite his mental illness, had been able to form clear criminal intent to kill two human beings.

“He killed in the delusional belief that the people he marked for death were ‘trying to steal his powers’ and that their actions would result in his death,” Idaho Deputy Attorney General Kenneth Jorgensen wrote in his brief to the court.

“The evidence at sentencing showed an escalation of violence in Delling’s behavior over time,” Mr. Jorgensen said. “Delling had, however, successfully hidden the extent of his delusional thinking from mental health specialists prior to the murders.”

Jorgensen also argued that Idaho law entitles convicted criminals who are insane to the same treatment as those who are civilly committed on grounds of insanity.

Delling’s lawyers said their client is not being afforded the same treatment as someone civilly committed. A patient who is civilly committed is entitled to be released after successful treatment, they said.

In contrast, Delling is being housed at Idaho’s Maximum Security Institution in solitary confinement, and must serve his full sentence even if his treatment is fully successful, Delling’s lawyers said.

The Idaho Supreme Court upheld Delling’s conviction, rejecting arguments that he should have been allowed to claim the insanity defense because he is incapable of appreciating the wrongfulness of his conduct.

“This disagreement over whether the Constitution mandates an insanity defense strikes at the heart of the integrity of the criminal justice system. And this case presents an ideal vehicle for resolving this issue,” Stanford law Prof. Jeffrey Fisher wrote in his brief urging the justices to take the Delling case.

“Almost every state, the District of Columbia, and the federal government continue to agree that punishing the insane offends the fundamental principle of justice that only those who are morally responsible for their actions may be convicted of serious crimes,” Professor Fisher wrote. “Idaho’s model …, flouts this principle and is at odds with both the weight of history and the modern consensus among the states.”

In his dissent, Breyer said the court should hear Delling’s appeal and examine whether Idaho’s modification of the insanity defense violates the 14th Amendment’s due process clause.

“The difference between the traditional insanity defense and Idaho’s standard is that the latter permits the conviction of an individual who knew what he was doing, but had no capacity to understand that it was wrong,” Breyer said.

The case was Delling v. Idaho (11-1515).  

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