181) The ALI test therefore added both a cognitive (intellectual) and volitional ("ability to choose or control") prong (182) to the test, while the M'Naghten rules only incorporated a cognitive aspect to the insanity defense test.
Other states attempted to create verdicts and methods to address the mentally ill in addition to the ALI test.
It changed the insanity defense from the ALI test, because the Act eliminated the volitional element that had broadened the insanity defense and allowed an individual to be found not guilty by reason of insanity if the individual could not "conform his conduct to the requirements of the law.
217) Thus, after the Hinckley acquittal and the subsequent passage of the IDRA, the majority of states moved away from the ALI test for insanity and back to variations of the stricter M'Naghten rule.
253) However, opponents of the ALI test (254) argue that it is too broad, because there is no certainty as to whether psychiatrists can "provide reliable data" on the volitional prong.
Idaho, however, recognized the inadequacy of the M'Naghten rule when applied to postpartum depression cases when it adopted the ALI test in State v.
30) Many states enacted a version of the ALI test prior to the Hinckley acquittal in 1982.
For a general discussion of the difference between the ALI test and the M'Naghten rules, see Diamond, supra note 30, at 9 and Elkins, supra note 21, at 162-70.
Interestingly, Congress, in revising the law of insanity following the Hinckley verdict, adopted a modified ALI test
stating that "the defendant as a result of a severe mental disease or defect, was unable to appreciate the nature and quality or the wrongfulness of his acts.