PROVO — A man who says God told him to gun down a dozen people can't hope to be found "not guilty by reason of insanity" if tried in Utah.

Neither could a Texas mother who drowned her children in a bathtub under the deluded belief that she was saving their souls from Satan.

But that verdict is an option in Texas. And on Wednesday, Andrea Yates was found not guilty by reason of insanity in her second murder trial for drowning her five children in 2001.

However, Utah is one of three U.S. states that have abolished the wording in the traditional insanity plea so those accused of murder can't claim they didn't know their actions were wrong.

"It's not a defense in Utah that you think you've been commanded by God to kill somebody," said Creighton Horton, chief of the Utah attorney general's criminal justice division. "You still know you're killing a human being."

Utah's mental-defense laws became tougher almost two decades ago when lawmakers removed the phrase "appreciating the wrongfulness of the act" from the law. The change makes it more difficult for attorneys to defend mentally ill clients.

Tom Means, head of the Utah County Public Defender Association, says it's "an uncommon defense.

"It's so rigorous," he said. "It's a very difficult defense to prove."

Means, though, is trying to do it. He's using the rare defense in the case of a man charged with first-degree murder for fatally shooting his brother in June 2005.

Eryk Drej told police he killed his brother to prevent him from killing another woman and selling her organs on the black market. In another bizarre act, Drej told officials he had placed "smiley faces" around his mother's American Fork home to warn his brother of impending danger.

After two competency reviews Drej was found competent to understand the legal proceedings. Now, however, mental health experts will be evaluating the 32-year-old man for his mental state at the time of the shooting.

Insanity laws in Utah

Utah and many other states tightened their insanity laws shortly after the attempted assassination of President Ronald Reagan in 1981. After a trial in 1983, shooter John Hinckley Jr. was found "not guilty by reason of insanity."

Defense attorneys cited an obsession with the movie "Taxi Driver" and its star Jodie Foster as the driving forces behind Hinckley's acts.

A backlash after the verdict pushed Congress and legislatures in many states to change their laws. Some states required that defense attorneys, not prosecutors, prove insanity. Others, like Utah, removed the insanity plea for defendants who argued that they saw nothing wrong in their actions.