Clark v. Arizona

548 U.S. 735 (2006)

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Nature of the Case

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Facts

Officer Jeffrey Moritz responded in uniform to complaints that a pickup truck with loud music blaring was circling a residential block. The officer turned on the emergency lights and siren of his marked patrol car, which prompted D, the truck's driver (then 17), to pull over. Officer Moritz got out of the patrol car and told D to stay where he was. Less than a minute later, D shot the officer, who died soon after but not before calling the police dispatcher for help. D ran away on foot but was arrested later that day with gunpowder residue on his hands; the gun that killed the officer was found nearby, stuffed into a knit cap. D was charged with first-degree murder for intentionally or knowingly killing a law enforcement officer in the line of duty. D was found incompetent to stand trial and was committed to a state hospital for treatment, but two years later the same trial court found his competence restored and ordered him to be tried. D waived his right to a jury, and the case was heard by the court. D did not contest the shooting and death but relied on his undisputed paranoid schizophrenia at the time of the incident in denying that he had the specific intent to shoot a law enforcement officer or knowledge that he was doing so, as required by the statute. P offered circumstantial evidence that D knew Officer Moritz was a law enforcement officer. The evidence showed that the officer was in uniform at the time, that he caught up with D in a marked police car with emergency lights and siren going, and that D acknowledged the symbols of police authority and stopped. D had intentionally lured an officer to the scene to kill him, having told some people a few weeks before the incident that he wanted to shoot police officers. The trial court denied D's motion for judgment of acquittal for failure to prove intent to kill a law enforcement officer or knowledge that Officer Moritz was a law enforcement officer. D claimed mental illness. He raised the affirmative defense of insanity, putting the burden on himself to prove by clear and convincing evidence, that 'at the time of the commission of the criminal act [he] was afflicted with a mental disease or defect of such severity that [he] did not know the criminal act was wrong.' He also aimed to rebut evidence of the requisite mens rea, that he had acted intentionally or knowingly to kill a law enforcement officer. The trial court ruled that D could not rely on evidence bearing on insanity to dispute the mens rea (Mott). The judge found that D shot and caused the death of Officer Moritz beyond a reasonable doubt and that D had not shown that he was insane at the time. D moved to vacate the judgment and sentence, arguing, among other things, that Arizona's insanity test and its Mott rule each violate due process. D claimed that the Arizona Legislature had impermissibly narrowed its standard in 1993 when it eliminated the first part of the two-part insanity test announced in M'Naghten's Case. The Court of Appeals of Arizona affirmed. The Supreme Court of Arizona denied further review. The Supreme Court granted certiorari to decide whether due process prohibits Arizona from thus narrowing its insanity test or from excluding evidence of mental illness and incapacity due to mental illness to rebut evidence of the requisite criminal intent.