SUPREME COURT OF MISSISSIPPI UPHOLDS M’NAUGHTEN AS STANDARD FOR INSANITY DEFENSE
12-10-19
The Journal of the American Academy of Psychiatry and the Law
In Ealey v. State, 158 So. 3d 283 (Miss. 2015), the Supreme Court of Mississippi affirmed a ruling of the Madison County Circuit Court that Sheila Ealey was sane, as established by substantial evidence, and denied her request to abandon M’Naughten. Ms. Ealey petitioned the court to replace M’Naughten with § 4.01 of the American Law Institute Model Penal Code. In addition to other assertions within her appeal, she proposed that the weight of the evidence did not substantiate a finding of sanity and that M’Naughten violated her due process rights. Consistent with past rulings, the court held that the M’Naughten Rule was the standard test for determining insanity in Mississippi pursuant to stare decisis.