Case #2: In the late 1970s, David Berkowitz killed six people in Westchester County, New York. Berkowitz generally went to teenage parking spots and killed lovers as they sat in their cars. When he was arrested, he confessed but claimed that he was acting on the orders of his neighbor's dog. Even though a psychiatrist that examined Berkowitz found him delusional and paranoid and his attorneys recommended an insanity defense, he pled guilty. Berkowitz later claimed to have made up the dog stories.

• At the time of Berkowitz's trial, which standard of insanity was in place?
• Do you think Berkowitz met that standard? Why?
• Where did the burden of proof lie during this time?