Citation. 306 Minn. 462,238 N.W.2d 851, 1976 Minn.
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Defendant was found guilty of careless driving and hit and run. Defendant argued that the Court’s failure to give an instruction on involuntary intoxication prejudiced his trial because at the time of the crime, he was on a prescription for Valium, a sedative.
Synopsis of Rule of Law.
To assert a defense of involuntary intoxication, a defendant may be excused from criminal liability only if he can be considered temporarily insane as defined by statute.
Facts.
Defendant was found guilty of careless driving and hit and run as to an attended vehicle. Defendant was not found guilty of assault. Defendant hit a garbage truck and then tried to escape, but his car was badly damaged and the police were able to arrest him. Defendant was first taken to the hospital where he ran away. Defendant hit the officer who eventually caught him. Defendant argued that his prescription for Valium made him unable to control his actions and that he did not remember anything he had done regarding the crimes in question. Defendant argued that he was involuntarily intoxicated.
Issue.
Whether failure to give an instruction regarding involuntary intoxication was prejudicial error and demands a new trial.
Held.
Reversed and remanded for a new trial.
There are four recognized types of involuntary intoxication: (1) coerced intoxication, (2) pathological intoxication, (3) intoxication by mistake, and (4) intoxication by prescription.
If a defendant is mentally deficient due to involuntary intoxication, then he may be excused from criminal liability only if temporarily insane as defined by statute.
Concurrence.
The concurrence agreed that there should have been instruction regarding involuntary intoxication. The concurrence used a separate definition than the majority and that the proper standard would be that Defendant must show he was incapable of exercising reasonable care in operating his car. The concurrence disagreed with the majority that Defendant would have to show temporary insanity.
Discussion.
The Court ruled that involuntary intoxication was an unusual condition and thus instructions for this defense would be rarely given. However, that in the instant case, Defendant was able to show that he had an unusual adverse reaction to the prescription and thus necessitated involuntary intoxication instructions. The Court ruled that the proper instruction would relate the involuntary intoxication to a standard that would equate the intoxication to temporary insanity. The Court explained why each of the four types of involuntary intoxication was allowable as a defense.
