Clark v. Arizona Ruling on Insanity Defense Didn’t Establish That Counsel Was Ineffective

The U.S. Supreme Court’s distinctions among types of insanity evidence in Clark v. Arizona, 548 U.S. 735, weren’t clearly established in prior law for purposes of the federal habeas corpus statute, the U.S. Court of Appeals for the Ninth Circuit held Oct. 8. (Clark v. Arnold, 2014 BL 282860, 9th Cir., No. 12-15601)

Clark v. Arizona Was Messy.

On direct appeal of the petitioner’s conviction for murdering a police officer, the Supreme Court rejected due process challenges to a state statute and court opinion that restricted the insanity defense and the types of evidence that may be ...