People v. Beaty, 19 N.Y.3d 918 (2012)
A defendant is entitled to an intoxication charge only when there is sufficient evidence in the record for a reasonable person to doubt whether the defendant formed the required intent due to intoxication; self-serving statements and the mere smell of alcohol are typically insufficient.
Summary
Defendant was convicted of rape and burglary. He argued that the trial court erred in denying his request for an intoxication charge, claiming he was too drunk to form the necessary intent. The New York Court of Appeals affirmed the conviction, holding that the evidence presented by the defendant—his own self-serving statements and the victim’s testimony that she smelled alcohol on his breath—was insufficient to warrant an intoxication charge. The Court emphasized that the defendant’s actions, such as cutting a screen, instructing the victim to be quiet, and stealing her phone, indicated purposeful behavior inconsistent with a lack of intent due to intoxication.
Facts
The victim returned home, charged her cell phone, and fell asleep. She was awakened by the defendant, who was lying next to her and smelled of alcohol. The defendant choked and raped her, threw a blanket over her head, and fled. The victim’s cell phone was missing. Police found cuts in the porch screen of the victim’s apartment. Ten days later, during questioning about another incident, the defendant was asked about the rape. A search warrant of defendant’s apartment revealed the victim’s cell phone hidden in the ceiling. Defendant gave a written statement claiming he had an alcohol problem and remembered knocking on the victim’s window but did not admit to the rape, claiming he fell asleep on the couch and fled when the woman screamed.
Procedural History
The trial court denied the defendant’s request for an intoxication charge. The jury convicted the defendant. The Appellate Division affirmed, holding that the defendant failed to establish his entitlement to an intoxication charge. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the trial court erred in denying the defendant’s request for an intoxication charge based on the evidence presented at trial.
Holding
No, because the defendant’s self-serving statements about his intoxication and the victim’s testimony that she smelled alcohol on his breath were insufficient to warrant an intoxication charge, especially in light of the evidence showing the defendant’s purposeful actions during the crime.
Court’s Reasoning
The Court of Appeals held that while intoxication is not a defense, evidence of intoxication is admissible to negate an element of the crime. An intoxication charge is required when “there is sufficient evidence of intoxication in the record for a reasonable person to entertain a doubt as to [an] element … on that basis” (People v. Perry, 61 N.Y.2d 849, 850 (1984). To meet this threshold, the defendant must present corroborating evidence beyond bare assertions, such as the number of drinks, the time frame of consumption, the lapse of time, whether alcohol was consumed on an empty stomach, the alcohol content of the drinks, and the specific impact of the alcohol on behavior or mental state (People v. Gaines, 83 N.Y.2d 925, 927 (1994).
The Court found the defendant’s statements about his intoxication were insufficient. The Court also noted that the defendant’s actions showed a purposeful intention. "[H]e cut a hole in a screen to gain entry, instructed the victim to be quiet, threw a blanket over her head, and stole her cell phone so she could not call the police. Given this evidence, the court correctly ruled an intoxication charge was not warranted." Thus, the evidence did not allow a reasonable juror to doubt the element of intent based on intoxication. The Court cited People v. Sirico, 17 N.Y.3d 744, 745 (2011), for the proposition that bare assertions of intoxication are insufficient to warrant the charge.