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The strict M ' Naghten standard for the insanity defense was used until the 1950s and the Durham v. United States case.
In the Durham case, the court ruled that a defendant is entitled to acquittal if the crime was the product of his mental illness ( i. e., crime would not have been committed but for the disease ).
The test, also called the Product Test, is broader than either the M ' Naghten test or the irresistible impulse test.
The test has much more lenient guideline for the insanity defense, but it addressed the issue of convicting mentally ill defendants, which was allowed under the M ' Naghten Rule.
However, the Durham standard drew much criticism because of its expansive definition of legal insanity.

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