Kansas adopted the "cognitive incapacity" test for the insanity defense, which examines whether a defendant was able to understand what he was doing when he committed a crime. A defendant may raise mental illness to show that he "lacked the culpable mental state required as an element of the offense charged," Kan. Stat. 21-5209. Otherwise, a defendant may use evidence of mental illness to argue for a lesser punishment. Kansas does not recognize a moral-incapacity defense, which asks whether illness left the defendant unable to distinguish right from wrong with respect to his criminal conduct. Kahler, charged with capital murder after he killed four family members, unsuccessfully argued that Kansas's insanity defense violated due process because it permits the conviction of a defendant whose mental illness prevented him from distinguishing right from wrong. Convicted, Kahler was sentenced to death. The Supreme Court affirmed. 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 (simplify like an 7th grader would speak0