State v. Crenshaw

Crenshaw and his wife were on their honeymoon in Canada. Crenshaw ended up getting deported as a result of his participation in a fight. He got a hotel in Blaine, Washington, and waited for his wife to join him. She arrived two days later and Crenshaw immediately thought that she had been unfaithful.

He did not ask her about it, instead he took her to the hotel room and beat her until she was unconscious. He then stole a knife from a store and returned to her, stabbing her 24 times. She did not survive the attack. Afterwards, Crenshaw drove to a nearby farm where he had been employed, borrowed an ax, and returned to the hotel room and decapitated her.

He proceeded to conceal his actions. He placed the body in a blanket, the head in a pillow case, and put both in his wife’s car. He cleaned the room of blood and fingerprints. He hid the body in a thick bush in a remote area. Crenshaw then drove 200 miles away from the scene of the crime and picked up two hitchhikers. He told them what he had done, and enlisted their aid in disposing of the wife’s car. The hitchhikers called the police. Crenshaw voluntarily confessed to the crime.

At trial, Crenshaw asserted an insanity defense. He testified that he followed the Moscovite religious faith, and that it would be improper for a Moscovite not to kill his wife if she had committed adultery. He also has a history of mental problems for which he has been hospitalized in the past for. The trial court gave a jury instruction that included: “for a defendant to be found not guilty by reason of insanity you must find that . . . the defendant . . . was unable to tell right from wrong.” Further, the trial court defined right and wrong as “knowledge of a person at the time of committing an act that he was acting contrary to the law.” The jury rejected the defense and he was found guilty of first degree murder.

Crenshaw appealed, arguing that the trial court erred in defining right and wrong as a legal right and wrong rather than in the moral sense.