The authorities have distinguished between an existing state of mental illness and a temporary episode of mental incapacity caused by the voluntary use of liquor or drugs. In the first instance, the defense of insanity is available even though the state of mental illness may have been brought about by excessive or prolonged use of liquor or drugs, but in the latter instance the defense is not available.
Appellant challenged his convictions for kidnapping and assault with a deadly weapon alleging that the trial court erred by refusing to submit the issue of insanity to the jury. The case was appealed to the Supreme Court of Arizona.
Is voluntary intoxication a valid defense to a crime in the state of Arizona?
The court held that though experts testified at trial that appellant did not know the nature and quality of his acts and that he did not know he was wrong at the time of the acts charged, the condition of the appellant's mind was caused by drug use and not insanity. It said that defendant's voluntary intoxication was not a defense to crime, but could be used to show lack of specific intent, about which the trial judge properly instructed the jury. The court held that the defendant did not allege an existing state of mental illness brought on by excessive drug use, but rather a temporary episode of mental incapacity caused by the voluntary use of drugs.