Daniel M'Naghten

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This page discusses the M'Naghten case. For the M'Naghten rules as a test of insanity, see M'Naghten Rules

Daniel McNaughton (his name is misspelt M'Naghten in the judgment) (1815? – 1865) was a Scottish woodsman who assassinated English civil servant Edward Drummond while suffering from paranoid delusions. Through his trial and its aftermath, he has given his name to a legal test of insanity in the UK and other common law jurisdictions (see M'Naghten Rules).

M'Naghten was, by all accounts, a textbook example of insanity. Due to a series of financial misfortunes, M'Naghten believed that he was the victim of an international conspiracy, involving the Pope and British Prime Minister, Robert Peel. He stalked Peel for days in London. On January 20, 1843, M'Naghten saw a figure he believed was Peel from the rear approaching Downing Street, and fired a single shot into his victim's back. The figure turned out to be Peel's secretary, Edward Drummond, who then walked to his brother's house nearby. Despite medical attention, Drummond died several days later.

Defended by one of London's best-known barristers, Alexander Cockburn, M'Naghten was found "not guilty by reason of insanity" in a jury trial, an acquittal that caused public unrest. Queen Victoria requested that M'Naghten's case be retried by the House of Lords. They then called on 15 judges of the common law courts, including Lord Chief Justice Tindal, to answer a series of questions regarding the law of insanity. From that discourse, the panel concluded that for insanity to apply as a defence, the defendant must either not know the nature of his act or not know that the act is wrong. Thus, M'Naghten would be found guilty even though his actions were motivated by insanity, since he knew the nature and wrongness of his act.

This formulation of the insanity requirement is known as the M'Naghten Rules. The M'Naghten rules became the basic test of insanity in England and were adopted by America and many countries throughout the British Commonwealth. The M'Naghten rules were employed with almost no modification by American courts and legislatures for more than 100 years, until the mid-20th century. In 1998, 25 states plus the District of Columbia still used versions of the M'Naghten rule to test for legal insanity.

Although acquitted of murder, the finding of insanity meant M'Naghten was forcibly institutionalized for the remainder of his life under the Criminal Lunatics Act 1800. He was initially remanded at Bethlem Royal Hospital, where he stayed for 20 years before being transferred to the Broadmoor Institution for the Criminally Insane. He died at Broadmoor in 1865.

Historical sources vary as to the correct spelling of M'Naghten's name. His signature supports a variety of hypothetical spellings, and in the manifold legal writings on the case, it is not uncommon to see McNaghten, M'Naughten, or some other variant.