"Homicidal mania must be proved, not assumed, nor confounded with reckless frenzy; To instruct, however, that it must be proved by 'clearly preponderating evidence' is error. All the authorities require is that the evidence proving it should 'fairly' preponderate.
"An attempt at suicide is not of itself evidence of insanity, and raises no legal presumption thereof....
"It was clearly proved that Coyle killed Emily Myers. That fact is admitted. The only defence set up is that he was insane at the time."
Rogers, Henry W. "Coyle v. Commonwealth: Insanity Proved by Evidence Fairly Preponderating." Am. L. Reg. 31 (1883): 191–8.