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State v Cameron
S. Ct. N. J.
Author:- Sam Biers
Voluntary Intoxication
Relevant Facts: Df approached the victim in a vacant lot while victim was playing cards. Df disrupted their game several times. The participants moved the table but the df continued and overturned the table. Then df attacked victim with a broken bottle and cut his hand open. When the police arrived she acted w/ violence toward them also.
Legal Issue(s): Whether the evidence was sufficient to require the jury to receive instruction on df’s intoxication?
Court’s Holding: No, insufficient.
Procedure: Indicted for 2nd degree agg. Assault. Poss of weapon w/ purpose to use it unlawfully; jury convicted on all; sentenced to seven yrs. Affirmed.
Law or Rule(s): Voluntary intoxication is a defense when it negates an essential element of the offense, that offense requiring specific intent of knowingly or purposefully.
Court Rationale: All three offenses required purposeful conduct as an element. The level of proof to demonstrate intoxication for purposes of demonstrating an inability to engage in purposeful conduct was not met. A showing of such a great prostration of the faculties that the requisite mental state was totally lacking is required. An accused must show that he was so intoxicated that he did not have the intent to commit an offense. Df testified she was drunk, and she felt pretty intoxicated, and pretty bad, are no more than conclusory labels. Df carried a quart of wine, that a pint had been drank out of it, with others, over an unknown period of time. There is not the slightest suggestion that df did not know what she was doing. She recited details regarding her claim of self-defense, with full recall and in explicit detail.
Plaintiff’s Argument: There is nothing in the record to deem sufficient to present a jury with a question of intoxication to a level satisfying the prostration of faculties test,
Defendant’s Argument: df was incapable of engaging in purposeful conduct.