Kahler v. Kansas

Brief Filed: 6/19
Court: U.S. Supreme Court 
Year of Decision: 2020

Read full-text amicus brief (PDF, 222KB)

Whether the eighth and fourteenth amendments require the states to recognize some form of the insanity defense in a criminal prosecution.

Insanity Defense

James Kahler, the petitioner, went to his ex-wife’s grandmother’s house on Thanksgiving 2009 and killed the grandmother, his ex-wife, and the couple’s two daughters. At trial, his lawyers offered evidence that he was suffering from major depressive and obsessive-compulsive disorders, among others. A defense expert testified that Kahler “felt compelled” to kill and was, for that period, “completely out of control.”

Under a revision to Kansas’ insanity defense statute, the jury was permitted to decide only whether Kahler had the intent to kill. They concluded he did and sentenced him to death. The state supreme court rejected his constitutional challenge to the limitations in the new insanity law.

APA (as it did in Clark v. Arizona, PDF, 216KBopens in new window) joined with the American Psychiatric Association to file a brief arguing that Constitutional Due Process rights are infringed by not allowing mentally ill defendants to present a traditional insanity defense.

On March 23, 2020, the U.S. Supreme Court affirmed the lower court decision, 6-3. In the opinion written by Justice Kagan, the Court held that due process does not require Kansas to adopt an insanity test that turns on a defendant’s ability to recognize that his crime was morally wrong. Justice Breyer filed a dissenting opinion, citing the brief APA participated in, in which Justices Ginsburg and Sotomayor joined.