Parsons v. State (1887) | Definition

Doc's CJ Glossary by Adam J. McKee
Course: Introduction / Criminal Law

Parsons v. State (1887) is an important Alabama Supreme Court case decided in 1887 that established the Irresistible Impulse Test of insanity.

Parsons v. State (1887) is a landmark case that shaped the way the law recognizes insanity as a defense in criminal trials. The case, decided by the Alabama Supreme Court in 1887, established the Irresistible Impulse Test, which is used in some jurisdictions as an alternative to the M’Naghten Rule.

The Facts in Parsons v. State

The case centered around a man named John Parsons, who was accused of murdering his wife. During the trial, Parsons’ defense argued that he was insane at the time of the murder and, therefore, not responsible for his actions. The prosecution countered that Parsons was fully aware of what he was doing and should be held responsible for his crime.

The trial court instructed the jury to consider whether Parsons was sane or insane at the time of the murder, according to the M’Naghten Rule. Under this test, Parsons would only be considered legally insane if he was so mentally ill that he could not understand the nature and quality of his actions or did not know that what he was doing was wrong.

However, the defense argued that Parsons was not insane under the M’Naghten Rule but was instead suffering from a mental disorder that caused him to experience an irresistible impulse to kill his wife. The defense argued that Parsons knew that what he was doing was wrong but could not control his actions due to the force of his mental disorder.

The trial court rejected the defense’s argument and instructed the jury to apply the M’Naghten Rule. The jury found Parsons guilty of murder, and he was sentenced to death.

The Appeal

Parsons appealed his conviction, and the case eventually made its way to the Alabama Supreme Court. In its decision, the court recognized that the M’Naghten Rule did not account for situations where a defendant knew their actions were wrong but could not control their behavior due to a mental illness.

A New Test of Insanity

The court established the Irresistible Impulse Test, which held that a defendant could be considered legally insane if they had an irresistible impulse to commit a crime due to a mental illness, even if they knew their actions were wrong. The court instructed lower courts to use this test when evaluating insanity defenses.

The Irresistible Impulse Test has been controversial and has been replaced by other tests in many jurisdictions. However, it remains an important part of the history of the insanity defense in the United States.

Parsons v. State (1887) established the Irresistible Impulse Test, which allowed for a broader understanding of the insanity defense in criminal trials. It recognized that mental illness could sometimes cause a person to commit a crime even if they knew it was wrong and that a narrow application of the M’Naghten Rule was not always appropriate. The case continues to be cited in legal discussions surrounding the insanity defense and has influenced the development of similar tests in other jurisdictions.

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Last Modified: 07/12/2023

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