People v. Williams, 39 N.Y.2d 758 (1976)
Evidence of a defendant’s prior instances of intemperance is inadmissible to prove the defendant’s intoxication or lack of specific intent at the time of the crime.
Summary
The New York Court of Appeals affirmed the defendant’s murder conviction, holding that the trial court properly instructed the jury to disregard evidence of the defendant’s prior drinking habits when determining whether the defendant was intoxicated at the time of the stabbing. The court reasoned that evidence of mere prior instances of intemperance is not probative of the defendant’s condition at the time of the crime. The court also upheld the trial court’s instruction regarding the consideration of expert testimony on causation.
Facts
The defendant stabbed Betty Williams through the heart on January 20, 1971. Williams died less than three months later. The defendant was charged with murder. At trial, the defendant’s sobriety at the time of the attack was a key issue. The court instructed the jury that they could consider any evidence on the subject of intoxication, but that any determination as to the defendant’s condition must be based on evidence and not on speculation. The court also instructed the jury that if the defendant was so intoxicated that he did not have the appropriate intent, he would not be guilty.
Procedural History
The defendant was convicted of murder. The Appellate Division affirmed the conviction. The defendant appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in instructing the jury to disregard evidence of the defendant’s prior drinking habits when determining whether the defendant was intoxicated at the time of the stabbing.
Holding
No, because evidence of mere prior instances of intemperance is not probative of the defendant’s condition or intent at the time of the crime.
Court’s Reasoning
The Court of Appeals reasoned that the trial court’s instruction was correct because evidence of mere prior instances of intemperance could not be considered in determining whether the defendant had the requisite intent or was in an intoxicated condition at the time of the stabbing. The court cited several prior cases supporting this principle, including Noonan v. Luther, Zucker v. Whitridge, and Cleghorn v. New York Cent. & Hudson Riv. R. R. Co. The court emphasized that evidence of specific instances of conduct relevant to the issue of intoxication at the time of the crime may be admissible, but general evidence of prior drinking habits is not. The court stated that the jury should “completely disregard any evidence as to what the defendant’s drinking habits were on other occasions,” and that this “admonition correctly informed the jury that evidence of mere prior instances of intemperance could not be considered in determining whether defendant had the requisite intent or was in an intoxicated condition at the time of the stabbing.” The court also noted that the trial court’s statement as to the consideration to be accorded to the testimony of the appellant’s medical expert on causation was not unfair or in error.