Brief Fact Summary.
The state appealed Sexton’s ability to use the insanity defense when he was found to be insane when he beat Ikeda to death under the use of LSD.
Synopsis of Rule of Law.
A defendant cannot use the insanity defense is the defendant was legally insane at the time of the offense due to the consumption of illegal drugs.
Ordinarily, proximate cause is a jury issue unless the proof is so clear that reasonable minds cannot draw different conclusions or where all reasonable minds would construe the facts and circumstances one way.View Full Point of Law
Sexton beat Ikeda to death while using LSD. Sexton was found to be insane during the event due to his LSD usage. Sexton was permitted to use the insanity defense and an interlocutory appeal was filed in the state supreme court to determine whether the insanity defense could be used in court.
Whether the insanity defense is sufficient if the defendant was legally insane at the time of the offense only due to the consumption of illegal drugs?
No. Sexton’s use of the insanity defense should be disallowed. Sexton’s use of LSD worsened his insane state, and the state cannot allow a defense of voluntary drug usage to satisfy the insanity defense because it would allow other defendants to get away with murder if they pled insanity due to their voluntary use of illicit drugs.
(Dooley, J.) The insanity defense should be allowed because individuals do not know that certain drugs will bring up mental conditions that they did not know they had. The permissive use of the insanity defense should be a fact-based inquiry.
The use of alcohol or drugs does not absolve the defendant of responsibility for actions that occur due to the result of the use of alcohol or drugs. Involuntary consumption of illegal drugs may be a defense, but is not the situation in this case. The defendant does not need to know whether or not the drugs cause the defendant to act insane.