Recent Supreme Court Rulings - Kahler v. Kansas

In the final pending Supreme Court case we will discuss this year, a tragically sad set of facts led to a question about the insanity defense.

Kraig Kahler was in the middle of a divorce with his wife and began suffering from depression and obsessive-compulsive disorder. He sought psychiatric treatment and was prescribed antidepressants, anti-anxiety medication, and sleep aids, but refused to take the medication as directed. After his divorce had been pending for some time, he went to his wife’s grandmother’s house, where they were visiting, and shot and killed his wife, two daughters, and his wife’s grandmother.

Experts who examined Kahler agreed that he suffered from major depressive disorder, obsessive-compulsive, borderline, paranoid, and narcissistic personality tendencies and a defense expert testified that, due to his mental illnesses, Kahler did not make the rational choice to kill his family and had “completely lost control.”

Under Kansas law, a jury cannot consider a mental disease or defect as a defense except to the extent that it shows “that the defendant lacked the mental state required as an element of the offense,” which essentially eliminates the insanity defense as it otherwise exists in most other states.

The question pending before the US Supreme Court was whether a state may abolish the insanity defense without violating the Eighth and Fourteenth Amendments right against cruel and unusual punishment?

The Supreme Court ruled that the Constitution’s Due Process clause does not require Kansas to “adopt an insanity test that turns on a defendant’s ability to recognize that his crime was morally wrong.”