State v. Delling, 267 P.3d 709

Delling was charged with two counts of first-degree murder, later amended to second-degree murder, and pleaded guilty conditionally to both counts.
He underwent a competency evaluation; initially found not fit to proceed, leading to commitment, then later found capable of aiding in his defense.
Delling moved to suppress mental-health evaluations and to declare I.C. § 18-207 unconstitutional, arguing violations of the 5th, 6th, 8th, and 14th Amendments and Idaho Constitution provisions.
The district court denied the constitutional challenge, ruling that abolishing insanity defense does not violate constitutional rights.
The district court sentenced him to determinate life for each second-degree murder count, to be served concurrently, after accepting his guilty pleas.
Delling timely appealed, arguing the abolition of the insanity defense is unconstitutional and that the sentence is excessive given his mental illness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of abolishing the insanity defense	Delling asserts due process and constitutional protections require an insanity defense.	Dellling contends I.C. § 18-207 abridges due process and Sixth/Eighth Amendment rights.	Abolition upheld; statute does not violate due process or Sixth/Eighth Amendment.
Impact of abolition on the Sixth Amendment right to present a defense	Insanity abolition deprives defendant of a meaningful defense via neuropsychiatric evidence.	Evidence of mental illness may rebut mens rea; no independent insanity defense required.	Statute does not violate the Sixth Amendment; mental-state evidence remains admissible.
Eighth Amendment challenges to punishment without insanity defense	Without insanity defense, punishment may be cruel or unusual for mentally ill defendants.	Idaho safeguards (competency, mens rea, and 19-2523 sentencing considerations) protect against punishment anomalies.	Abolition does not violate the Eighth Amendment; statutory safeguards ensure constitutional compliance.

State v. Searcy, 118 Idaho 632 (1990) (upheld constitutionality of I.C. § 18-207)
State v. Card, 121 Idaho 425 (1991) (upheld § 18-207 within murder conviction context)
State v. Winn, 121 Idaho 850 (1992) (insanity defense in non-capital cases not required to be constitutional issue)
State v. Moore, 126 Idaho 208 (1994) (reiterated validity of 18-207 under stare decisis)
Card, 121 Idaho 429 (1991) ( Idaho safeguards at sentencing and competency considerations)
Clark v. Arizona, 548 U.S. 735 (2006) (limited examination of insanity defense; states retain definitional authority)