State v. Korell

The State of Montana (plaintiff) prosecuted Jerry Korell (defendant) for attempted deliberate homicide and aggravated assault. Montana had recently passed a statute eliminating insanity as a full affirmative defense that would absolve a mentally ill defendant of all criminal responsibility; instead, a defendant claiming insanity had to undergo evaluation by a court-appointed psychiatrist, the jury could consider mental illness only as it bore on the defendant's state of mind, and a judge could consider it only at sentencing. At trial, evidence showed Korell acted under paranoid delusions but still had the mental capacity to act knowingly and purposely, and the jury convicted him. Korell appealed, arguing the statute violated the Fourteenth Amendment's due process guarantee and the Eighth Amendment's ban on cruel and unusual punishment.