285) While some have argued that postpartum psychosis can satisfy the cognitive aspect of the M'Naghten test because it can "deprive a defendant of her ability to distinguish right from wrong at the time of the act," (286) others suggest that the M'Naghten rule poses obstacles for women attempting to use the insanity defense.
293) In this case, the court adopted the M'Naghten rule and found the defendant guilty.
Idaho, however, recognized the inadequacy of the M'Naghten rule when applied to postpartum depression cases when it adopted the ALI test in State v.
166) The court determined that if the M'Naghten rule
Although England did not codify the insanity test in the M'Naghten rules until 1843, various cultures have excused mentally ill individuals from criminal responsibility.
In 1962, the American Law Institute published the Model Penal Code, which combined the strictly cognitive M'Naghten rules and the irresistible impulse test.
Montana, Utah and Idaho abolished the insanity defense altogether; other states adopted the more stringent M'Naghten rules over the Model Penal Code definition of insanity; several states shifted the burden of proof from the prosecution to the defense; and 14 states offered an alternative to NGRI, which is the guilty but mentally ill verdict.
The M'Naghten Rules
, with their focus on delusions understood as wrong beliefs, clearly reflected contemporary psychiatric preoccupations, but transformed the psychiatric foci into distinctly legal constructs widely perceived by psychiatrists to be at odds with the fundamentals of psychiatric understanding (see Teubner, 1989:748-9; see also Forshaw and Rollin 1990:75-101).
13) Named for the particularly controversial case which inspired their creation, the M'Naghten Rules stipulated that a defendant was not legally responsible for his crime if at the time he committed the crime he "was labouring under such a defect of reason, from disease of the mind, as 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.
16) Not only did the M'Naghten Rules inspire debate between and within the legal and medical professions, but they fell far short of eliminating public doubt about the legitimacy of the insanity acquittal.
Was it a case of juries inflexibly adhering to the M'Naghten Rules when dealing with male defendants, and assessing female defendants more subjectively?
However, many women acquitted on ground of insanity knew both that they had committed a crime and that it was wrong, as demonstrated by their immediate confessions to family, friends and the police, and this points to the fact that, while the medical and legal professions wrestled one another for authority over the insanity acquittal, many juries essentially ignored the M'Naghten Rules in order to grant insanity acquittals to deserving female defendants who did not meet the rules' criteria.