Scenario

Police officers are called to the house at 268 South Main Street after a neighbor notices newspapers piling up at the front door.The house is occupied by Carl, his wife Becca, and two small daughters, Dani and Lori. The neighbor states that he has not seen Carl or his family for several days and is worried about them. A police patrol drives by the house and notices a car in the driveway and four newspapers on the front porch. The house is quiet, and no movement is seen inside the home.

Two police officers go to the front door and ring the doorbell. There is no answer. The police officers walk around the house and look through the windows to see if they can see anything. As a police officer peers through the kitchen window, she sees a body lying on the kitchen floor. The police officers kick open the backdoor and enter the house. They check the body of an adult female lying on the kitchen floor, and it is obvious that she has been deceased for days.

The police officers immediately seal off the crime scene and call homicide detectives. The homicide detectives process the crime scene by taking photographs of the entire house and then collecting various pieces of potential evidence. The detectives learn by speaking with the neighbors that Carl works for a construction company and is frequently out of town on jobs. Another neighbor identifies the body of Becca when shown a picture of her.

A detective is able to contact Carl by using Becca's cell phone. Carl states that he is in a neighboring town on a construction site and has been there for the past four days. The detective asks Carl to immediately drive home. While waiting for Carl to arrive, the detective looks at Becca's text messages and notices no communication between Carl and Becca for the past five days. Older text messages reveal a hostile relationship with numerous disagreements and fighting. In the text messages, Becca frequently threatens to leave Carl and tells him that he will never see his daughters again. There are also discussions about Carl's "girlfriend" who evidently works for the construction company.

Carl arrives home and the detectives inform him that his wife has been killed. Carl appears distraught but agrees to speak with the detectives. Carl states that he has no idea who would do such a thing and that neither Becca nor he has any enemies. Carl told the detectives that Becca was watching a movie when he left for the construction site, and his daughters were spending a week with friends. Carl lives in a hotel room close to the construction site and hasn't seen or spoken with his wife since he left for work four days ago.

An autopsy of Becca reveals that she was killed by multiple stab wounds. The knife used was approximately six inches in length. The coroner estimates that Becca had been deceased for about four days.

After an investigation, Carl is arrested by detectives and charged with murder. He is held without bail in the local prison.

Rose, a criminal defense attorney, has been assigned to represent Carl at his upcoming criminal trial. You are Rose's paralegal and will assist her with the case. Carl has been charged with one count of first-degree murder. There are numerous evidentiary issues associated with this case. Rose and you meet the next morning and begin to comb through the police reports, crime scene photographs, and evidence collected.

Question

During your discussions with Carl, Rose and you become concerned that Carl may have mental health issues. As a member of the defense team, you (under Rose's guidance) must explore all possible defenses. Rose decides to get Carl evaluated by a psychiatrist to see if the insanity defense may be an option. Explain to Carl what the insanity defense is, as defined in your state's law (California), its burden of proof, and how you think juries view the insanity defense in California.