Brief Fact Summary.
Defendant appeals a conviction of kidnapping and assault with a deadly weapon and sentenced to concurrent terms of thirty years to life on both charges.
Synopsis of Rule of Law.
In Arizona, voluntary intoxication is not a defense to a crime but may be admissible to show lack of specific intent.
In the past, Arizona has uniformly adhered to what is known as the Rule of M'Naghten's Case as the test for criminal insanity.View Full Point of Law
Eugene Raymond Cooper (Defendant) was driving recklessly through a shopping center parking lot when he was pursued by a police officer. Defendant led the police officer on a high-speed chase during rush hour traffic. Defendant shot and wounded the pursuing police officer and then kidnapped a man in a parking lot at gunpoint. The kidnapped man wrestled the gun away from Defendant and the vehicle crashed into the divider on a freeway. Although Defendant attempted to run, he was quickly apprehended and charged with kidnapping and assault with a deadly weapon. At the request of Defendant’s counsel, the court appointed psychiatrists to examine Defendant’s mental condition prior to trial. The psychiatrists reported that Defendant was competent to stand trial. Defendant’s counsel then timely gave notice of his intention to raise the defense of insanity at trial. During the trial, Defendant’s counsel offered testimony from a psychiatrist and a psychologist as to Defendant’s mental condition at the time of the offense. Both experts testified that had Defendant not been on amphetamines for several days prior to the offense, he would have been sane. After hearing the testimony, the trial judge held that the evidence did not raise an issue as to Defendant’s sanity and would not be heard by the jury. Further, the trial judge refused all of Defendant’s jury instructions related to the issue of a defense of insanity. Defendant was convicted of kidnapping and assault with a deadly weapon and sentenced to concurrent terms of thirty years to life on both charges. He appealed.
Whether voluntary intoxication is a defense to a crime. In Arizona, voluntary intoxication is not a defense to a crime but may be admissible to show lack of specific intent.
No. Defendant’s conviction is affirmed.
Arizona has long adhered to the M’Naghten Rule as the test of insanity. To rebut the presumption of sanity the defendant must introduce sufficient evidence to generate a doubt as to his sanity. If there is sufficient evidence, the burden shifts back to the State to prove sanity beyond a reasonable doubt. Here, Defendant argues that the testimony provided by both the psychiatrist and psychologist met that burden, and if it had been allowed to be presented to the jury, would have supported a finding that Defendant was insane at the time of the offense. While the State concedes that each of Defendant’s expert witnesses testified that Defendant did not know the nature and quality of his acts and that he did not know he was doing wrong at the time of the offense, but the State argues that Defendant’s mind was altered by drugs, not a mental disease or defect, at the time of the events and such evidence is not permitted under the state’s insanity defense. Voluntary intoxication, whether by alcohol or drugs, is not a defense to crime, but evidence of such intoxication is admissible to show lack of specific intent. Here, Defendant’s condition was the result of an artificially produced state of mind brought on by his own hand at his own choice. Consequently, Defendant’s burden to overcome the presumption of sanity was not met.