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Kahler v. Kansas

Updated Sep 18, 2026

In brief

Kansas may keep its rule: the Supreme Court said the Constitution does not require an insanity defense based on inability to recognize moral wrongness.

Where it stands
Decided

Decided 6-3 · March 23, 2020 · Opinion by Justice Kagan

What it’s about
This case asked whether Kansas could limit the insanity defense so that mental illness could negate criminal intent, but could not excuse a defendant who understood what he was doing yet could not tell right from wrong.
Who it affects
The decision leaves Kansas's approach in place. It says the Constitution does not require the state to excuse a defendant who, because of mental illness, could not recognize that the crime was morally wrong.

Summary: written with AI from the case record.

Illustration for Kahler v. Kansas
Conceptual illustration · AI-generated

What it's about

The Supreme Court upheld Kansas’s law, ruling that the Constitution does not require states to adopt a traditional moral-capacity insanity defense.

The case tested how much freedom states have to decide when mental illness excuses criminal responsibility.

Question presented

Do the Eighth and Fourteenth Amendments permit a state to abolish the insanity defense?

What the Court decided

Holding

Due process does not require Kansas to adopt an insanity test that turns on a defendant’s ability to recognize that his crime was morally wrong. 307 Kan. 374, 410 P. 3d 105, affirmed.

Result
Affirmed

The vote

  • Joined the judgment
  • Dissented
  • Wrote an opinion
Majority · 6joined the Court's opinion
  1. Kaganwrote the opinion
  2. Roberts
  3. Thomas
  4. Alito
  5. Gorsuch
  6. Kavanaugh
Dissenting · 3disagreed with the result
  1. Breyerwrote the dissent
  2. Sotomayor
  3. Ginsburg
6 justices joined the judgment, 3 dissented.

From the opinions

“But here, Kansas has not simply redefined the insanity defense.”

— Justice Breyer(dissent)

What's next

The Supreme Court's review is complete, and the Kansas Supreme Court's ruling remains in place.

Documents

4

Docket activity

7
  • New analysis added

    Sep 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 18, 2026 · Generated

  • AI analysis generated: Decision Record

    Sep 18, 2026 · Generated

  • Opinion added: opinion

    Mar 23, 2020 · Court records

  • Brief added: Petition

    Sep 28, 2018 · Court records

Show 2 more
  • Court Order added: Lower Court Orders/Opinions

    Jun 29, 2018 · Court records

  • Brief added: Questions Presented

    Court records

More questions

3
What did Kahler v. Kansas decide?
The Supreme Court upheld Kansas's ruling and said due process (constitutional fairness) does not require an insanity defense for not knowing right from wrong.
How did Kansas's rule treat mental illness?
It could remove criminal intent, but it did not excuse someone who understood the act yet could not tell right from wrong.
Who wrote the Court's opinion in Kahler v. Kansas?
Justice Kagan wrote the opinion, signed by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. Justice Breyer disagreed in a separate opinion, signed by Justices Ginsburg and Sotomayor.

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Sep 18, 2026Methodology

Court records and filings

Reporting and analysis