City of Minneapolis v. Altimus
Supreme Court of Minnesota, 1976.
Author: Jim

Facts: Defendant was involved in a hit and run accident. The jury found him guilty of careless driving and hit and run.  Defendant argues that the trial judge erred by not instructing the jury on the defense of involuntary intoxication.  Defendant claims that his doctor prescribed to him Valium to cure his back pain and after he took this medicine, it started to have strange effects on him and at the time of the accident, he was in this condition.

Issue: Did the trial court err by not instructing the jury on the defense of involuntary intoxication?

Holding: Yes

Rule: There are 4 kinds of involuntary intoxication:

1. coerced intoxication
2. pathological intoxication
3. intoxication by innocent mistake
4. intoxication resulting from ingestion of a medically prescribed drug

For intoxication resulting from prescribed drug, the defendant must meet 3 elements:

1. The defendant must not know, or have a reason to know, that the drug will have such effects on him.
2. The prescribed drug is the cause of the intoxication and not something else.
3. The defendant due to this intoxication is temporarily insane.

Rationale: A jury has to decide whether these 3 elements are met and the defendant in the current case should have had the instruction of involuntary intoxication.