State v. Cameron

Brief Fact Summary.

Cameron (Defendant) was not permitted to use voluntary intoxication as a defense to charges of assault, illegal weapon possession, and resisting arrest. She appealed her resulting conviction.

Synopsis of Rule of Law.

Voluntary intoxication can be a defense to crimes that require a “knowing” or “purposeful” act.

Facts.

Defendant was involved in an altercation with several individuals. As a result, she was charged with assault, illegal weapon possession, and resisting arrest. Defendant tried to raise a defense of voluntary intoxication, but the court did not allow it. Defendant was convicted and appealed. A state court of appeals reversed the conviction and the state supreme court granted review.

Issue.

Is voluntary intoxication a defense to crimes that require a “knowing” or “purposeful” act?

Held.

(Clifford, J.) Yes. Voluntary intoxication can be a defense to crimes that require a “knowing” or “purposeful” act. Common law applied the defense of voluntary intoxication only to specific intent crimes and not to general intent crimes. New Jersey enacted a statute changing the culpability element of criminal law. Mens rea has four categories: “knowing,” “purposeful,” “reckless,” and “criminally negligent.” Voluntary intoxication can be raised as a defense to “knowing” and “purposeful” crimes. The assault, illegal weapon possession, and resisting arrest offenses fall within those categories, so the defense is applicable. (The court then ruled that, as a matter of law, the evidence of voluntary intoxication was insufficient to go to a jury and reinstated the conviction.)

Discussion.

Voluntary intoxication has been used as a complete defense to negate an element of the offense in question, or as an incomplete defense to reduce a charge. Recently, the trend has been to allow it only in cases where it operates as a complete defense.