Clark v. Arizona

Facts

Police Officer Moritz responded to multiple complaints that a pickup truck was blaring music and circling a residential block. Moritz turned on his emergency lights and siren of is marked police car and pulled over the truck. The Defendant, Clark, was the driver of the truck. Less than a minute after being pulled over, the Defendant shot Moritz and he died soon after.

The Defendant was charged with first-degree murder for intentionally or knowingly killing a law enforcement officer in the line of duty. At trial, the Defendant did not contest shooting and killing Moritz, but relied on his paranoid schizophrenia at the time of the incident in denying that he had the specific intent or knowledge as required by the statute. The prosecutor offered circumstantial evidence that the Defendant knew Moritz was a law enforcement officer. The testimony offered for the prosecution indicated that the Defendant intentionally lured an officer to the scene in order to kill him and that he told people a few weeks prior to the incident that he wanted to shoot police officers.

In presenting his defense, the Defendant claimed mental illness and sought to introduce it for two purposes. First, he raised the affirmative defense of insanity. Under Arizona law, this put the burden on the Defendant 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. Second, he tried to rebut the prosecution’s evidence of the requisite mens rea, that he had acted intentionally or knowingly to kill a law enforcement officer.