City of Minneapolis v. Altimus
1976 Minn. LEXIS 1480, 238 N.W.2d 851, 306 Minn. 462 (1976)
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Rule of Law:
Involuntary intoxication from a medically prescribed drug is a valid defense to a criminal charge if the intoxication causes a temporary insanity, meaning the defendant was laboring under such a defect of reason as to not know the nature of their act or that it was wrong.
Facts:
- On September 25, 1973, defendant Robert Altimus saw a doctor at the Veterans Administration Hospital for a back problem and the flu.
- The doctor prescribed the drug Valium, a skeletal muscle relaxant, which Altimus took as directed.
- On September 28, 1973, Altimus, while driving, made an illegal left turn and crashed into a garbage truck.
- Altimus immediately backed up and drove away slowly from the scene of the collision.
- When police stopped him a block away, Altimus appeared confused, gave a false name, and later testified he remembered nothing about the accident or the events that followed.
- Altimus's doctor testified that while drowsiness and confusion are normal side effects of Valium, hyperexcitability is a rarer, but possible, side effect.
- After being taken to the hospital, Altimus fled and was involved in altercations with police before being apprehended.
Procedural Posture:
- Defendant was tried before a jury in Hennepin County Municipal Court (trial court).
- The jury found defendant guilty of careless driving and hit and run as to an attended vehicle, and not guilty of simple assault.
- The trial court sentenced the defendant to concurrent terms of 30 and 90 days in the workhouse.
- Defendant appealed the judgment of conviction to the Supreme Court of Minnesota.
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Issue:
Did the trial court err by refusing to instruct the jury on the defense of involuntary intoxication when the defendant presented evidence that his criminal acts may have resulted from an unexpected reaction to a prescribed medication?
Opinions:
Majority - Kelly, Justice
Yes, the trial court erred in refusing to instruct the jury on the defense of temporary insanity due to involuntary intoxication. While voluntary intoxication is only a defense to specific-intent crimes, involuntary intoxication can be a complete defense. The court recognized four types of involuntary intoxication, including unexpected intoxication from a medically prescribed drug. To successfully assert this defense, a defendant must prove by a preponderance of the evidence that: 1) they did not know or have reason to know the prescribed drug would have an intoxicating effect; 2) the prescribed drug was the cause of the intoxication; and 3) the intoxication resulted in temporary insanity as defined by Minnesota statute § 611.026, meaning the defendant was laboring under such a defect of reason as not to know the nature of their act or that it was wrong. Because Altimus presented sufficient evidence of an unexpected reaction to Valium to raise the defense, he was entitled to the instruction, and its absence was prejudicial error requiring a new trial.
Concurring - Rogosheske, Justice
Yes, a new trial is required, but the majority's reasoning is flawed. Involuntary intoxication should not be analyzed as a form of insanity under Minn. St. § 611.026. This defense is rooted in the common law principle of mens rea, which requires conscious, volitional fault for criminal liability. The proper test should be the one articulated in the Model Penal Code: whether the defendant, by reason of such intoxication, lacked substantial capacity to appreciate the criminality of his conduct or to conform his conduct to the law. Equating this state with mental illness or deficiency stretches the meaning of the insanity statute beyond its legislative intent and improperly constrains a defense based on lack of criminal intent.
Analysis:
This case establishes involuntary intoxication as a cognizable defense in Minnesota but significantly limits its application by tethering it to the state's strict, M'Naghten-based insanity test. Instead of adopting a more modern, volitional test like the Model Penal Code, the court requires the defendant to prove a cognitive defect (not knowing the nature or wrongfulness of the act). This creates a high evidentiary burden for defendants and solidifies a cognitive, rather than a volitional, approach to intoxication defenses. The special concurrence highlights the fundamental tension between viewing the defense as a lack of mens rea versus a form of insanity, a debate central to modern criminal law.
