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State v Cooper
S. CT. AZ 1974
Author:- Sam Biers
Voluntary Intoxication
Relevant Facts: Df was reported to police for driving recklessly. When a patrolman pursued him, df shot and wounded the officer. Df then kidnapped a man at gunpoint. The victim wrestled the gun away and they crashed the car on the freeway. Df had been drinking heavily and under the influence of amphetamines for several days prior. He attempted to flee but was apprehended.
Legal Issue(s): Whether voluntary intoxication is a valid defense under the insanity rule?
Court’s Holding: No.
Procedure: Convicted of kidnapping, assault w/ deadly weapon, 30 yrs to life for each offense. Affirmed.
Law or Rule(s): If Df did not know the nature and quality of his acts and he did not know that what he was doing was wrong at the time of the acts charged, he was insane.
Court Rationale: There is a presumption of sanity in every criminal case. The df must introduce sufficient evidence to generate doubt as to his sanity. Experts testified that w/o the use of the drugs during the time in question the df would have been sane. It was the use of the drugs which induced his mental incapacity. Insanity as a defense is available only with an existing mental illness or one brought about by excessive or prolonged use of intoxicants, but a temporary episode of mental incapacity caused by the voluntary use of drugs is not available as a defense. Voluntary actions of the df do not provide an excuse in law for his subsequent irrational conduct.
Plaintiff’s Argument: The condition of the df’s mind was caused by the df’s use of drugs and this does not constitute the defense of insanity.
Defendant’s Argument: The expert testimony supported a finding that the df was insane at the time of the commission of the criminal acts charged.