Commonwealth v. Graves

Brief Fact Summary. The Defendant, Daniel Lee Graves (Defendant), was convicted by a jury of first-degree murder, robbery and burglary. The Defendant claimed not to have recalled the events leading to the charges, as he was on LSD and had drunk wine that day.

Synopsis of Rule of Law. Evidence of voluntary intoxication may be used to prove that the defendant could not have formed the requisite mental state for the crime committed.

Facts. The Defendant and his cousins, Thomas and Edward Mathis, burglarized the home of the victim, Sebastiano Patiri and robbed him. The victim sustained injuries during the burglary and robbery that resulted in his death. The Defendant claimed that on the day of the incident, he consumed a quart or more of wine and had taken LSD. The Defendant claims that this rendered him unconscious and he suffered limited amnesia resulting in him having no recollection of the events leading to the victim’s death.

Issue. Can the defense of voluntary intoxication be used to negate the specific intent elements of the offenses of burglary and robbery in addition to negating the specific intent to commit murder?

Held. Yes. While the Pennsylvania Supreme Court had previously held that voluntary intoxication can negate the specific intent to kill required by the crime of murder in the first degree, voluntary intoxication had not been available to defeat the specific intent element of other crimes. The Pennsylvania Supreme Court determined, however, that the defense of voluntary intoxication must be extended to all specific intent crimes. Logically, since the prosecution must prove every element of an offense beyond a reasonable doubt, the Defendant must be able to produce relevant evidence to contest the intent element of the offense.

Dissent. Any person who voluntarily ingests intoxicants must be held to intend the consequences of his actions.

Discussion. Proof of voluntary intoxication may negate the specific intent element of the crimes charged.