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Criminal Law Keyed to Lee
Clark v. Arizona
Citation:
548 U.S. 735, 126 S.Ct. 2709, 165 L.Ed.2d 842 (2006)Facts
Police responded in uniform to complaints of a truck with loud music blaring. The driver of the truck, Eric Clark, was ordered to pull over by a police vehicle. An officer got out of the police vehicle and told Clark to stay where he was. However, less than a minute later, Clark shot the officer, who died soon after. Clark ran away on foot but was arrested later that day.
Clark was charged with first degree murder. In March 2001, Clark was found incompetent to stand trial and was committed to a state hospital for treatment. Two years later, the same court found his competence restored and a new trial was ordered.
At his trial, he did not contest the shooting and the death. Instead, he asserted an insanity defense and he relied on his undisputed paranoid schizophrenia at the time of the incident. He argued that he could not fulfill the required mens rea of the offense, given his cognitive incapacity. The trial court held that he could not rely on evidence bearing on insanity to dispute the mens rea for first degree murder. He was found guilty. Clark appealed, arguing that the trial court violated his due process.
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