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Assignment 4

The document discusses two criminal law cases related to intoxication as a defense. In the first case, the court ruled that a defendant could be found criminally negligent despite intoxication. In the second case, the court upheld the constitutionality of a state law limiting the intoxication defense.

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Amber Smith
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18 views

Assignment 4

The document discusses two criminal law cases related to intoxication as a defense. In the first case, the court ruled that a defendant could be found criminally negligent despite intoxication. In the second case, the court upheld the constitutionality of a state law limiting the intoxication defense.

Uploaded by

Amber Smith
Copyright
© Attribution Non-Commercial (BY-NC)
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Criminal Law

Assignment 4

8/31/2010

State v. Coates
Relevant Facts Coates, the defendant, wrecked his blue thunderbird into another car in a hit and run in front of an off-duty policeman. Long, the policeman caught up to the defendant and insisted he return to the wrecked car. After seeing a police car at the wreck site, the defendant stabbed Officer Long twice in the back before returning to his own car. Clearly, the defendant was very drunk and proved this with a BAC of .16 4 hours after the wreck and assault of the officer. Coates maintained that he did not remember any of this and is not liable for his actions because he could not form intent while inebriated. Procedural History The jury found the defendant not guilty of second degree assault but guilty of assault in the third degree. He appealed the conviction based on the jury instruction; he disagreed that this[intoxication] defense applies only where the mental state is intent, knowledge, or recklessness specifically precluding the jury from applying the alcohol defense to the third degree assault charge. Issue Presented Can a defendant argue lack of intent during a period of intoxication? Also, is voluntary intoxication an affirmative defense? The statute seems to contradict itselfintoxication does not make an act less criminal, yet it may be taken into consideration by the jury when determining mental state. Holding The majority of the en banc ruled that the defendant was criminally negligent despite his intoxication. The proper way to deal with the issue was to instruct the jury that is may consider evidence of the defendants intoxication in deciding with the mental state. Reasoning Criminal negligence is defined as a persons failure to be aware of a substantial risk that a wrongful act may occur. Coates knew the risks of drinking and was guilty of criminal negligence. ALSO, another judge concurred with the ruling but disagreed with the application of criminal negligence on the case. He believed that the actors state of mind was completely irrelevant, the intoxication, all that matters is what a reasonable person would have donetherefore he was negligent. Dissent- the dissenting opinion held that the changed working in statutes meant that the intoxication defense was extended to all crimes in which one of the four mental states constitutes an element of crime. Judgment/Disposition Affirmed

Commonwealth v. Rumsey
Relevant Facts A prison inmate got drunk on bootleg alcohol and assaulted guards by swinging scissors at them. He maintains that he was unable to form the requisite criminal intent for assault by a prisoner because of his intoxication. Procedural History Appellant contends that section 308 of the Pennsylvania Penal Code limiting the defense of intoxication in criminal proceedings was unconstitutional. Issue Presented Is section 308 constitutional? The statute reads, neither voluntary intoxication nor drugged condition is a defense to a criminal charge except whenever its relevant to lower a murder charge. The defendant has to clearly, plainly, and palpably show that the law violates either PA or the USs constitutions. Holding It is constitutional to have a state law limiting the intoxication defense. Much like strict liability cases, the enforcement of intoxicated crimes imposes responsibility to better prevent the consequences. Reasoning The court ruled that the legislature has to right to redefine what constitutes mens rea. The past case rulings on the matter vary greatly in allowing the intoxication defense to show lack of mens rea. Also, the law in 1973, which was repealed, was ruled by the courts to allow the use of the intoxication defense to negate intentionally or knowingly. Judgment/Disposition Affirmed

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