America's First M'Naghten Defense and the Origin of the Black Rage Syndrome.

Abstract

The 1843 M'Naghten verdict led to reformulation of the British criminal insanity standard, which American jurisdictions noted. In 1846, New York State tried William Freeman for slaying several members of the Van Nest family at their home near Auburn, New York. Mr. Freeman had been obsessed with false imprisonment for horse theft. His defense attorney, former governor William Seward, sought an insanity verdict, citing reaction to racist maltreatment as the cause. Though Mr. Freeman was impaired, a jury found him competent to stand trial. The competency adjudication created confusion in the trial court about the admissibility of medical testimony on criminal responsibility, resulting in exclusion of key psychiatric findings. Meanwhile, the interracial killings caused a sensation in the press, which vilified the defendant. Again, the defense argued that maltreatment created mental illness. A second jury convicted Mr. Freeman and the judge sentenced him to death. Seward filed a Writ of Error, and the New York State Supreme Court reversed the conviction, clarifying competency versus criminal responsibility and proclaiming the M'Naghten Rule as the standard in New York. A century later, attorneys cited Mr. Freeman's dynamics to explain and mitigate the violent actions of some African-Americans. We examine the insanity defense during the 1840s and explore twentieth-century "black rage" reverberations of the Freeman case.