The Irresistible Impulse Test
By Linda Sanabria, J.D. | Legally reviewed by Melissa Bender, Esq. | Last reviewed December 05, 2023
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Mental illness can erode the power to make a voluntary choice between ethical and wrongful actions. The court in Parsons found that a person may face a compulsion driven by the "duress of such mental disease."
The insanity plea plays a crucial role in criminal prosecutions. It provides a legal avenue to excuse defendants facing mental health challenges. It's an important tool to ensure that the criminal justice system doesn't punish someone whose actions are caused by severe mental illness, but the courts often grapple with defining insanity and establishing proof.
This article delves into the complexities surrounding insanity defenses, with a focus on the irresistible impulse test. Unlike the M'Naghten Rule, the Irresistible Impulse Test evaluates not only an individual's awareness of right and wrong but also their capacity to resist impulses leading to unlawful behavior.
Definition of the Irresistible Impulse Test
The irresistible impulse test is a component of many tests for the insanity defense. Under this rule, the defendant can be found not guilty if they prove that, as a result of mental illness, they were unable to control their impulses at the time of the crime, even if they knew that committing the criminal act was illegal or morally wrong.
This test emerged as a response to criticisms directed at the M'Naghten Rule. Many scholars argued that the definition of insanity should extend beyond mental competency. Unlike the M'Naghten Rule, the irresistible impulse test goes beyond looking at a defendant's awareness of right and wrong. It also evaluates their capacity to resist impulses leading to unlawful acts.
History of the Irresistible Impulse Test
The irresistible impulse test dates back to the 19th century. It was first applied by the Alabama Supreme Court in the landmark case of Parsons v. State. In this decision, the court introduced a new perspective on criminal responsibility.
The court held that, due to the overpowering influence of a mental defect, a defendant could be competent enough to discern right from wrong and still be exempt from culpability.
At the time of the alleged crime, the defendant's free agency had been obliterated by the profound impact of a disease of the mind.
The court linked the criminal act and the mental disorder. This established a cause-and-effect relationship where the mental disease was the cause of the offense. It also recognized the influence mental disorders exerted over a defendant's decision-making process.
Ultimately, the court's decision in Parsons v. State set a precedent that, in some cases, the defendant could be found not guilty by reason of insanity. This marked a significant departure from traditional assessments of criminal responsibility. It also paved the way for a more nuanced understanding of mental illness, free will, and culpability in criminal cases.
Proving Irresistible Impulse
In jurisdictions where it is recognized as an affirmative defense, defendants seeking to prove irresistible impulse are generally required to demonstrate two key elements:
- Existence of mental illness: The first element involves proving the presence of mental illness.
- Causation of inability to control actions: The second element involves establishing a causal link. This link is between the diagnosed mental illness and the defendant's incapacity to control their actions. This requires proof to show how mental illness directly contributed to the inability to exercise control.
Proving that a defendant lacked control over their actions poses a formidable challenge. The process can include medical evaluation and expert opinions from specialists in mental health. The evidence presented must affirm the existence of a diagnosed mental condition. It must also show its specific impact on the defendant's behavior. The evidence should note environmental factors that may have triggered the condition.
Criticism of the Irresistible Impulse Test
The irresistible impulse test was an important corrective to M'Naghten's cognitive bias. However, it still came under some criticism of its own.
For example, the test made the definition of insanity too broad for some. It didn't cover the impossibility of determining which acts were uncontrollable rather than merely uncontrolled. Some argued it also made it easier to fake insanity.
The test was also criticized for being too narrow. Like M'Naghten, the test seemed to exclude all but those unable to control their actions. Nevertheless, several states use this test and the M'Naghten Rule to determine insanity. The American Law Institute adopted a modified version of it for the Model Penal Code definition of insanity.
Questions About the Irresistible Impulse Test or Legal Insanity? Ask a Criminal Defense Attorney
The defense of insanity usually requires medical confirmation from an expert. Sometimes, other requirements are necessary. Do you have any questions or concerns regarding legal insanity? Discuss your case with a local criminal defense attorney for legal answers.
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