State v. Cameron

Gary Cameron (defendant) stabbed his stepmother 97 times and left her body in the bathtub, the knife sticking in her heart. Cameron claimed God ordered the killing because his stepmother was an agent of Satan who was persecuting him. Cameron knew what he was doing violated the law, but he believed he was following a higher directive from God. Before trial, Cameron requested acquittal on insanity grounds. Three psychiatrists and a psychologist testified that Cameron had paranoid schizophrenia at the time of the killing and the time of trial. All four agreed that Cameron believed he was a messiah or agent of God required to carry out God’s directives and believed that God had commanded him to kill his stepmother as an evil spirit. As a result, the doctors agreed that Cameron was legally insane at the time of the murder. However, the trial judge denied the motion to acquit and instead submitted the insanity issue to the jury. The judge instructed the jury using the Washington pattern instruction on insanity, which specified that acquittal required finding that a mental disease or defect made the accused “unable to perceive the nature and quality of the acts” charged or “unable to tell right from wrong.” The judge also added a sentence the Washington courts had approved in another case: “What is meant by the terms ‘right and wrong’ refers to knowledge of a person at the time of committing an act that he was acting contrary to the law.” The jury convicted, and the appellate court affirmed. Cameron appealed to the Washington Supreme Court, arguing the sentence the trial judge added to the pattern jury instruction prevented the jury from considering moral right and wrong, instead of only legal right and wrong.