Law School Case Brief
People v. Whitfield - 7 Cal. 4th 437, 27 Cal. Rptr. 2d 858, 868 P.2d 272 (1994)
Evidence of voluntary intoxication is admissible under Cal. Penal Code § 22 with regard to the question whether the defendant harbored malice aforethought, whether such malice is express or implied.
Convicted three times for driving under the influence of alcohol, defendant Stephen Martin Whitfield was involved in a head-on collision with another vehicle, which resulted in the death of the other driver. At his murder trial in California state court, Whitfield argued that he did not harbor implied malice because he was so intoxicated that he was unconscious when the accident occurred. The jury found him guilty of second-degree murder. On appeal, the court of appeals affirmed, rejecting Whitfield's claim that the jury should have been charged on involuntary manslaughter. The appellate court ruled that the trial court erred in Whitfield's favor by instructing the jury that it could consider his degree of intoxication in deciding whether he harbored implied malice. Whitfield appealed, challenging the trial court's refusal to instruct the jury on involuntary manslaughter if it found he was unconscious as a result of voluntary intoxication without the intent to kill or malice at the time of the killing.
Should trial court have instructed the jury on involuntary manslaughter if it found that Whitfield was unconscious as a result of voluntary intoxication without the intent to kill or malice at the time of the automobile accident?
The state supreme court affirmed the appellate court's judgment. The court held that the jury was properly instructed because Whitfield's intoxication was admissible under Cal. Penal Code § 22 for the jury to find he acted with the culpable mental state for a specific intent crime; the jury found he acted with implied malice by exposing the public to his dangerous driving. The court held that Whitfield's requested charge was properly refused because it implied that, if he was unconscious when the collision occurred, he could not be convicted of murder.
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