United States v. Freeman (1966)

Charles Freeman (defendant), with a long history of drug and alcohol abuse, was arrested for selling heroin to undercover officers and found competent to stand trial, but argued he lacked capacity for criminal responsibility. The district court applied the traditional M'Naghten test, under which incapacity requires a mental disease making the defendant unable to know the nature and quality of his acts or that they were wrong. Freeman's expert testified Freeman suffered psychosis, delusions, hallucinations, and brain trauma from drug use and boxing, but conceded Freeman knew he was selling heroin, even if he did not know it was wrong; the government's expert testified Freeman could still, with limitations, distinguish right from wrong. The trial judge found Freeman's incapacity insufficient under M'Naghten and convicted him, and Freeman appealed.