New York Law Review

Tag: Intoxication defense

  • People v. Beaty, 19 N.Y.3d 918 (2012): Entitlement to Intoxication Charge in Criminal Cases

    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.

  • People v. Heidgen, 22 N.Y.3d 896 (2013): Intoxication and Depraved Indifference

    People v. Heidgen, 22 N.Y.3d 896 (2013)

    Voluntary intoxication, even to the point of extreme inebriation, does not automatically preclude a finding of depraved indifference in crimes such as assault or murder, particularly in cases involving drunk driving; however, the lack of evidence to support all elements of depraved indifference assault warrants a reduction in culpability.

    Summary

    The defendant, heavily intoxicated, drove the wrong way on a parkway, causing a head-on collision. He was initially convicted of first-degree depraved indifference assault, based on his actions of becoming intoxicated knowing he would drive. The Appellate Division reversed this conviction, deeming his state of mind too remote from the crash. The Court of Appeals affirmed the reduced charge of second-degree assault due to insufficient evidence of depraved indifference, but Justice Graffeo’s concurrence addressed the question of whether extreme intoxication could negate a finding of depraved indifference, noting legislative efforts to address this issue in vehicular crimes.

    Facts

    The defendant drove the wrong way on a Long Island parkway while heavily intoxicated (three times the legal limit). Despite warnings from other drivers, he continued and caused a head-on collision, injuring others. His blood alcohol level was .18% or higher. After the accident, when informed he had injured people, he responded with indifference.

    Procedural History

    The defendant was indicted for multiple offenses, including first-degree depraved indifference assault. The trial court found insufficient evidence of depraved indifference at the time of the collision due to the defendant’s extreme intoxication, but convicted him based on his earlier decision to drive while intoxicated. The Appellate Division reversed the first-degree assault conviction. The Court of Appeals affirmed the reversal, reducing the conviction to second-degree assault.

    Issue(s)

    Whether the voluntary consumption of alcohol to the point of extreme inebriation precludes the formation of a depravedly indifferent state of mind, particularly in the context of vehicular assault.

    Holding

    No, not necessarily because voluntary intoxication does not automatically negate a finding of depraved indifference; however, in this specific case, the evidence was insufficient to prove all elements of depraved indifference assault, warranting the reduced charge.

    Court’s Reasoning

    Justice Graffeo, in her concurrence, highlighted the evolution of understanding depraved indifference from an objective standard to a subjective state of mind, as established in People v. Feingold. She acknowledged that while Penal Law § 15.25 allows intoxication to negate an element of a crime, voluntary intoxication typically doesn’t excuse recklessness, and it may not excuse “extreme recklessness… that is needed to establish depraved indifference” (People v. Baker, 14 NY3d 266, 273 [2010]). She argued that exonerating someone from the consequences of their actions simply because they became extremely drunk serves no social or penological purpose. She cited that driving an automobile along a crowded sidewalk at high speed is one quintessential example of depraved indifference. Justice Graffeo noted that legislative changes in 2006 and 2007, including the creation of aggravated vehicular assault and homicide, aimed to address the difficulty of proving depraved indifference in vehicular crimes due to intoxication claims. She emphasized the need for the legislature to clarify whether intoxication can serve as a defense to depraved indifference crimes, offering potential legislative solutions such as amending Penal Law § 15.05 or including specific provisions in assault and murder statutes for intoxicated drivers. She stated, “there is no social or penological purpose to be served by a rule that permits one who voluntarily drinks to be exonerated from failing to foresee the results of his conduct if he is successful at getting drunk” (People v Register, 60 NY2d at 280-281).

  • People v. Newton, 8 N.Y.3d 460 (2007): Intoxication is Not a Defense When a Crime Lacks a Mens Rea Element

    People v. Newton, 8 N.Y.3d 460 (2007)

    Intoxication is not a defense to a crime when the crime does not require a specific mental state (mens rea), such as intent, because intoxication can only negate the formation of a specific intent.

    Summary

    Defendant was convicted of third-degree sodomy. At trial, the judge declined to instruct the jury that intoxication could be considered as a defense to the charge of third-degree sodomy, because that crime does not require a specific mental state. The New York Court of Appeals affirmed, holding that because third-degree sodomy only requires that a reasonable person in the defendant’s situation would have understood the victim’s words and acts as an expression of a lack of consent, the defendant’s actual subjective understanding is irrelevant, and thus evidence of intoxication is also irrelevant.

    Facts

    The defendant was accused of engaging in oral sex with a 19-year-old male. The victim allegedly did not resist or verbally communicate a lack of consent. The defendant claimed he perceived the act to be consensual. The defendant had been drinking beer for several hours before the incident.

    Procedural History

    The defendant was indicted on charges of sodomy in the first degree, sexual abuse in the first degree, and sodomy in the third degree. At trial, the court instructed the jury on intoxication only with respect to the first-degree sodomy charge. The jury acquitted the defendant of first-degree sodomy but convicted him of third-degree sodomy. The Appellate Division affirmed the judgment of conviction, and the New York Court of Appeals affirmed as well.

    Issue(s)

    Whether evidence of intoxication is relevant to the crime of third-degree sodomy when the crime requires an objective assessment of whether a reasonable person in the defendant’s situation would have understood the victim’s words and acts as an expression of a lack of consent?

    Holding

    No, because a defendant’s subjective mental state is not an element of the crime of third-degree sodomy, evidence of intoxication at the time of the sexual act is irrelevant.

    Court’s Reasoning

    The Court of Appeals reasoned that Penal Law § 130.40 (3) requires the defendant to have engaged in the sexual act “with another person without such person’s consent where such lack of consent [was] by reason of some factor other than incapacity to consent.” The statute defines “lack of consent” as “circumstances under which, at the time of the [sexual act], the victim clearly expressed that he or she did not consent to engage in such act, and a reasonable person in the actor’s situation would have understood such person’s words and acts as an expression of lack of consent to such act under all the circumstances” (Penal Law § 130.05 [2] [d]).

    The court emphasized the objective element of the statute: “Although the ‘reasonable person’ must stand in the shoes of the actor, if such a person would understand that the victim was expressing a lack of consent, then it does not matter that the accused thought otherwise.”

    The court reasoned that allowing evidence of intoxication would essentially require the prosecution to prove the defendant’s subjective understanding, which is not an element of the crime. The court stated, “Otherwise, it would not be enough for a victim simply to say ‘No.’ Every prosecution would devolve into a dispute over whether the particular defendant might have misapprehended whether ‘No’ really meant ‘No’ for one reason or another.”

    Because the crime does not require a specific mental state that could be negated by intoxication, the trial court properly declined to instruct the jury on intoxication with respect to the charge of third-degree sodomy.

  • People v. Butler, 84 N.Y.2d 627 (1994): Intoxication Instruction and Lesser Included Offenses

    84 N.Y.2d 627 (1994)

    A trial court’s decision to give an intoxication instruction does not automatically require the court to also give lesser-included offense instructions; the decision to give lesser-included offense instructions must be based on an independent evaluation of the evidence.

    Summary

    Sidney Butler was convicted of second-degree murder and criminal possession of a weapon. The Appellate Division reversed, finding the trial court erred in refusing to instruct the jury on the lesser-included offense of first-degree manslaughter after giving an intoxication instruction. The Court of Appeals reversed, holding that an intoxication instruction does not automatically trigger an obligation to instruct on lesser-included offenses. The court emphasized that each instruction must be independently justified by the evidence presented and that the brutality of the crime indicated intent rather than recklessness or intent to only seriously injure. The case was remitted to the Appellate Division for further proceedings.

    Facts

    The victim, Anderson, spent the evening socializing before meeting Butler and her cousin at a taxi dispatcher’s office. The group consumed alcohol, marijuana, and cocaine. The dispatcher ended the gathering, and a taxi took Anderson and Butler to Anderson’s apartment. Anderson was discovered semiconscious outside her apartment the next morning, covered in blood, and later died from head injuries and 34 stab wounds. Butler was arrested and charged with murder.

    Procedural History

    Butler was convicted in Westchester County Court. The Appellate Division reversed the conviction, ordering a new trial because the trial court refused to instruct the jury on manslaughter in the first degree, despite giving an intoxication instruction. The dissenting Justice at the Appellate Division granted the People leave to appeal to the Court of Appeals.

    Issue(s)

    Whether a trial court’s decision to give an intoxication instruction automatically requires the court to give lesser-included offense instructions within the homicide classification, specifically manslaughter in the first and second degrees.

    Holding

    No, because an intoxication instruction does not mechanically trigger a corresponding obligation for the trial court to give complementary lesser-included offense instructions. The decision to give lesser-included offense instructions must be based on the appraisal of the particular evidence, not pure logic.

    Court’s Reasoning

    The Court of Appeals reasoned that CPL 300.50 requires a reasonable view of the evidence to support a finding that the defendant committed the lesser offense but not the greater. The court emphasized the importance of evidentiary assessment, stating, “the evidence of the particular case, not pure or abstract logic, governs.” The court distinguished this case, noting the brutality of the crime (34 stab wounds, 9 of which were fatal) indicated an intent to kill, not merely to cause serious injury or act recklessly. The court also highlighted that if the jury believed the intoxication evidence, they should have acquitted the defendant of murder, not found him guilty of a lesser offense. The court stated that allowing the jury to decide that defendant acted recklessly would be contrary to the rational and common sense view of the evidence. The dissent argued that the trial court should have instructed the jury on manslaughter in the second degree (reckless homicide) because, under Penal Law § 15.05(3), evidence of intoxication cannot be used to negate recklessness. The majority rejected this, concluding that the ferocity of the attack precluded a finding of recklessness, and the crime was “intentional murder in the second degree or nothing.”

    Notably, the court stated: “In the end, the burden remains always on the People to establish beyond a reasonable doubt that defendant, despite the possible effect of the arguable intoxication evidence, was capable of and did form the necessary intent to kill.”

  • People v. Koerber, 84 N.Y.2d 923 (1994): Sufficiency of Evidence for Intoxication Defense Instruction

    People v. Koerber, 84 N.Y.2d 923 (1994)

    A jury instruction on intoxication is warranted only if there is sufficient evidence in the record for a reasonable person to doubt the element of intent based on intoxication; a bare assertion of intoxication is insufficient.

    Summary

    Defendant Koerber was convicted of second-degree assault following an altercation. He argued that the trial court erred in refusing to provide an intoxication instruction to the jury. The New York Court of Appeals affirmed the conviction, holding that the defendant’s testimony was equivocal and lacked specific details about his alcohol consumption needed to support a reasonable doubt regarding his intent due to intoxication. The Court emphasized the need for corroborating evidence beyond a mere claim of being intoxicated.

    Facts

    Koerber and a prostitute hired a driver, Boyd. An altercation ensued regarding payment. Koerber admitted to hitting Boyd, excusing his actions by stating he “may have lost control” because he “had a couple of drinks and [he] just got ripped off or whatever.” Upon arrival, officers witnessed Koerber kicking Boyd, who was older and smaller. The defendant requested an intoxication instruction, which the trial court denied.

    Procedural History

    The Supreme Court convicted Koerber of assault in the second degree. The Appellate Division affirmed the judgment, finding insufficient evidence to warrant an intoxication charge. A Justice of the Appellate Division granted leave to appeal to the Court of Appeals.

    Issue(s)

    Whether the trial court erred in refusing to instruct the jury on the defense of intoxication, pursuant to Penal Law § 15.25, given the defendant’s claim that he was intoxicated at the time of the assault.

    Holding

    No, because the defendant’s evidence lacked the requisite details tending to corroborate his claim of intoxication, and therefore, a reasonable person could not entertain a doubt as to the element of intent based on intoxication.

    Court’s Reasoning

    The Court of Appeals affirmed the Appellate Division’s decision, emphasizing that while the evidence must be viewed in the light most favorable to the defendant when evaluating whether a particular defense theory should have been charged, a mere assertion of intoxication is insufficient. The court cited People v. Perry, 61 NY2d 849, 850, stating, “A charge on intoxication should be given if there is sufficient evidence of intoxication in the record for a reasonable person to entertain a doubt as to the element of intent on that basis.” The court found that Koerber’s evidence lacked crucial details, such as the number of drinks, the time frame of consumption, the time lapse between consumption and the event, whether alcohol was consumed on an empty stomach, the alcohol content of the drinks, and the specific impact of alcohol on his behavior or mental state. The court referenced People v. Rodriguez, 76 NY2d 918, 921, noting that neither the prostitute’s statement that the defendant was “high” nor the police officer’s observation of glassy eyes and alcohol on his breath added sufficiently to warrant the intoxication instruction. The court emphasized that the defendant needed to provide specific facts about his intoxication, not just a vague claim, to warrant the instruction. The absence of such details made it impossible for a reasonable person to doubt the element of intent due to intoxication, justifying the trial court’s refusal to give the instruction.

  • People v. Allen, 69 N.Y.2d 915 (1987): Preserving Objections to Jury Instructions on Intoxication

    People v. Allen, 69 N.Y.2d 915 (1987)

    A general objection to a jury instruction, without specifying the grounds, is insufficient to preserve the issue for appellate review.

    Summary

    Defendant Allen was convicted of second-degree murder. On appeal, he argued that the trial court’s jury instruction on intoxication violated his due process rights by improperly shifting the burden of proof or unduly emphasizing credibility. However, the Court of Appeals affirmed the conviction, holding that Allen’s general objection to the instruction at trial was insufficient to preserve the issue for appellate review because he did not specifically articulate the basis for his objection to the trial judge. The court emphasized that specific and timely objections are needed to allow the trial court to correct any errors.

    Facts

    The defendant, Barry Allen, was convicted of murder in the second degree. During the trial, jury instructions regarding intoxication were given. The specific facts surrounding the murder itself are not detailed in this memorandum opinion, as the appeal focuses solely on the propriety of the jury instructions.

    Procedural History

    The defendant was convicted of murder in the second degree in the trial court. He appealed to the Appellate Division, which affirmed the conviction. He then appealed to the New York Court of Appeals.

    Issue(s)

    1. Whether the trial court erred in denying reinstruction on intoxication in the supplemental charge to the jury when the jury only asked for reinstruction on the elements of the crime charged.
    2. Whether the defendant adequately preserved for appellate review his objection to the primary instruction on intoxication, framed as a violation of due process, when his objection to the Trial Judge was unparticularized.

    Holding

    1. No, because the jury did not request reinstruction on intoxication, but only on the elements of the crime charged.
    2. No, because the defendant’s objection to the intoxication instruction was unparticularized and did not specify the grounds for the objection.

    Court’s Reasoning

    The Court of Appeals held that the defendant’s argument concerning the failure to re-instruct on intoxication was without merit because the jury only requested reinstruction on the elements of the crime. More importantly, the court addressed the defendant’s objection to the initial intoxication instruction. The court emphasized the need for specific objections at trial to allow the trial judge an opportunity to correct any potential errors. Here, the defendant’s objection was deemed too general. The Court stated that the objection was “not so framed as an objection expressed to the Trial Judge, and is not adequately preserved by the unparticularized objection to the intoxication instruction.” By failing to articulate the specific basis for his objection—namely, that the instruction shifted the burden of proof or unduly emphasized credibility—the defendant forfeited his right to raise the issue on appeal. The Court of Appeals effectively reinforced the contemporaneous objection rule, which requires parties to raise objections at the time of the alleged error to preserve the issue for appellate review. This rule prevents “sandbagging” the trial court and ensures fairness to both parties. The court did not elaborate further, issuing a memorandum opinion, implying the issue was well-settled.

  • People v. Blim, 63 N.Y.2d 718 (1984): Jury Instructions on Lesser Included Offenses When Evidence Supports It

    People v. Blim, 63 N.Y.2d 718 (1984)

    A court must instruct the jury on a lesser included offense if a reasonable view of the evidence would support a finding that the defendant committed the lesser offense but not the greater offense.

    Summary

    The defendant was convicted of burglary. At trial, the court denied the defense’s request to charge the jury on the lesser-included offense of criminal trespass. The Appellate Division reversed, ordering a new trial. The Court of Appeals affirmed, holding that the jury should have been instructed on the lesser-included offense because, based on the defendant’s intoxication, a reasonable jury could have concluded that he committed trespass but lacked the specific intent required for burglary. The court emphasized that the evidence must be viewed in the light most favorable to the defendant when determining whether to give a lesser included offense instruction.

    Facts

    Shortly after midnight on December 18, 1979, police arrested the defendant as he fled from an auto supply store. He was charged with third-degree burglary. The defendant testified that he had been drinking heavily in the 12 hours leading up to his arrest and did not remember being at the store. Other witnesses corroborated the defendant’s intoxicated state on the evening of his arrest and immediately thereafter.

    Procedural History

    The trial court denied the defense’s request to instruct the jury on the lesser-included offense of third-degree criminal trespass. The jury convicted the defendant of burglary. The Appellate Division reversed the conviction and ordered a new trial, stating the reversal was based on the law, even though the order mentioned the facts. The People appealed to the New York Court of Appeals.

    Issue(s)

    Whether the trial court erred in refusing to instruct the jury on the lesser-included offense of criminal trespass in the third degree, given the evidence presented at trial regarding the defendant’s intoxication.

    Holding

    Yes, because a reasonable jury could have concluded that the defendant committed the act of trespass but, due to intoxication, lacked the specific intent required for a burglary conviction.

    Court’s Reasoning

    The Court of Appeals held that trespass in the third degree is a lesser-included offense of burglary in the third degree, citing People v. Henderson, 41 N.Y.2d 233, 235. The court stated the rule: “the trespass count should have been charged if, under any reasonable view of the evidence, a jury could find that defendant committed the lesser offense but not the greater (see CPL 300.50, subds 1, 2; see, also, People v. Scarborough, 49 NY2d 364; People v. Johnson, 45 NY2d 546).” The court emphasized that when determining whether a reasonable view of the evidence exists, it must be viewed in the light most favorable to the defendant, citing People v. Shuman, 37 N.Y.2d 302. The Court reasoned that the jury could have found that the defendant knowingly entered or remained unlawfully in the building (committing trespass) but also concluded that he was too intoxicated to form the specific intent to commit a crime within the building, which is a prerequisite for burglary. Therefore, it was error to refuse the lesser-included offense instruction. The court implied that the Appellate Division correctly identified the error of law, despite also alluding to facts in their decision, and affirmed their decision to order a new trial.

  • People v. Lee, 35 N.Y.2d 826 (1974): Preserving Objections to Jury Instructions for Appellate Review

    People v. Lee, 35 N.Y.2d 826 (1974)

    To preserve an objection to a jury instruction for appellate review in New York, the party must make their position known to the court at a time when the court has an opportunity to correct the error.

    Summary

    Defendant Lee appealed his conviction, arguing that the trial court’s jury instruction regarding intoxication as a defense was erroneous because it referred to the voluntary use of drugs when he claimed his drug use was involuntary. The New York Court of Appeals affirmed the Appellate Division’s order, holding that the defendant failed to preserve this specific objection at trial. The Court emphasized that the defendant only took a general exception to the charge on intoxication, without specifically objecting to the characterization of drug use as voluntary. Because the defendant did not give the trial court an opportunity to correct the alleged error, the issue was not properly preserved for appellate review.

    Facts

    The defendant, Lee, was charged with a crime. At trial, Lee claimed his actions were caused by unknowingly ingesting LSD that had been added to his Coca-Cola. He requested a jury instruction that intoxication is a defense if it prevents the defendant from forming the required criminal intent. The trial judge’s charge included references to the voluntary use of drugs and its impact on the defendant’s capacity to form the necessary criminal intent.

    Procedural History

    The defendant was convicted at trial. He appealed to the Appellate Division, arguing that the jury instruction was erroneous. The Appellate Division affirmed the conviction. The defendant then appealed to the New York Court of Appeals. The Court of Appeals affirmed the Appellate Division’s order, finding the error was not preserved for review.

    Issue(s)

    Whether the defendant preserved for appellate review the objection that the trial court incorrectly characterized his drug use as voluntary in its jury instruction on intoxication.

    Holding

    No, because the defendant did not make his position known to the trial court at a time when the court could have corrected the instruction.

    Court’s Reasoning

    The Court of Appeals held that the defendant failed to preserve the objection regarding the characterization of drug use as voluntary because he only made a general exception to the intoxication charge. The Court relied on CPL 470.05 (subd 2), which requires a party to make “his position with respect to the * * * instruction known to the court” at a “time when the court had an opportunity of effectively changing the same.” Because the defendant did not specifically object to the voluntary nature of the drug use at trial, the trial court was not given the opportunity to correct the alleged error. The court also addressed the denial of a continuance, determining that the decision was within the trial judge’s discretion.

  • People v. Williams, 39 N.Y.2d 758 (1976): Admissibility of Prior Intemperance to Prove Intoxication

    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.

  • People v. Stanfield, 36 N.Y.2d 467 (1975): Duty to Charge Lesser Included Offenses Based on Intoxication

    People v. Stanfield, 36 N.Y.2d 467 (1975)

    A trial court must charge a lesser included offense if, upon any reasonable view of the evidence, the jury could find the defendant guilty of the lesser offense and not the greater.

    Summary

    The New York Court of Appeals reversed the defendant’s first-degree murder conviction, holding that the trial court erred in refusing to charge manslaughter in the second degree. The Court reasoned that based on evidence of the defendant’s intoxication and the bizarre nature of the crime, the jury could have reasonably concluded that the defendant lacked the intent necessary for murder or first-degree manslaughter. Therefore, the defendant was entitled to have the jury consider the lesser included offense of manslaughter in the second degree.

    Facts

    The 69-year-old defendant stabbed a previously unknown victim on the sidewalk. There was some evidence presented that the defendant was intoxicated at the time of the stabbing. Following the killing, the defendant’s behavior was described as bewildered and ingenuous. The defendant was charged with murder in the first degree, manslaughter in the first degree, and assault in the first degree.

    Procedural History

    The defendant was convicted of murder in the first degree. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the trial court erred in refusing to charge the jury on the lesser included offense of manslaughter in the second degree, given evidence of the defendant’s intoxication and the circumstances of the crime.

    Holding

    Yes, because based on the evidence of the defendant’s intoxication and the lack of a plausible explanation for the stabbing, the jury could have reasonably concluded that the defendant did not possess the requisite intent for murder or first-degree manslaughter.

    Court’s Reasoning

    The Court of Appeals relied on the principle that a defendant is entitled to the most favorable view of the record when determining whether to charge a lesser included offense. Citing People v. Battle, the Court stated, “On the duty of the court to charge the lesser degree of [the crime], defendant is entitled to the most favorable view of the record.” The Court also referenced People v. Mussenden, emphasizing that “[I]f, upon any view of the facts, a defendant could properly be found guilty of a lesser degree or an included crime, the trial judge must submit such lower offense.”

    The Court found that the evidence of the defendant’s intoxication, combined with the seemingly inexplicable nature of the attack, provided a basis for the jury to find that the defendant lacked the intent to kill or cause serious physical injury. The Court highlighted the lack of any apparent motive or prior connection between the defendant and the victim. Given these circumstances, the Court concluded that the trial court’s refusal to charge manslaughter in the second degree was reversible error. The court emphasized that the jury could have found that “at the time of the stabbing defendant was too intoxicated to have intended either to kill his victim or to cause her serious physical injury.”

    The Court did not address any dissenting or concurring opinions as none were recorded.