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Commonwealth v. Collins

Superior Court of Pennsylvania
2002 Pa. Super. 344, 810 A.2d 698, 2002 Pa. Super. LEXIS 3220 (2002)
ELI5:

Rule of Law:

For strict liability offenses such as Driving Under the Influence (DUI), which do not require proof of a culpable mental state, the defendant bears the burden of proving the affirmative defense of involuntary intoxication by a preponderance of the evidence.


Facts:

  • On March 17, 2001, Jennie Collins stopped at a mini-market on her way to pick up a friend, Megan Neff.
  • At the mini-market, acquaintances invited Collins to a party, where she drank something that 'tasted like fruit punch.'
  • About fifteen minutes later, Collins left the party and picked up Neff, complaining of a headache.
  • While driving with Neff, Collins became non-conversational, drove past their destination, and ran through five or six stop signs without stopping.
  • Collins began to swerve into oncoming traffic and gave no indication she heard Neff yelling at her to stop.
  • After Collins applied the brake, Neff steered the car off the road, at which point Collins appeared to lose consciousness.
  • At the hospital, a urine sample from Collins tested positive for phencyclidine (PCP).

Procedural Posture:

  • The Commonwealth charged Jennie Collins with Driving Under the Influence of a Controlled Substance and Failure to Comply With Duties at a Stop Sign in a Pennsylvania trial court.
  • Following a trial, a jury found Collins guilty of driving under the influence.
  • The trial judge found Collins guilty of the summary offense of failing to obey a stop sign.
  • The trial court sentenced Collins to a period of incarceration, electronic home monitoring, safe driving classes, and a fine.
  • Collins appealed the judgment of sentence to the Superior Court of Pennsylvania, an intermediate appellate court.

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Issue:

Does a jury instruction that requires a defendant to prove the affirmative defense of involuntary intoxication by a preponderance of the evidence violate the presumption of innocence or the Pennsylvania Crimes Code when the charge is Driving Under the Influence?


Opinions:

Majority - Johnson, J.

No. A jury instruction requiring a defendant to prove the affirmative defense of involuntary intoxication by a preponderance of the evidence does not violate the presumption of innocence or the Pennsylvania Crimes Code for a DUI charge. The court reasoned that the burden of proving an affirmative defense may be placed on a defendant when the defense does not negate an element of the crime charged. The elements of DUI under 75 Pa.C.S. § 3731(a)(2) are (1) operating a vehicle and (2) being under the influence of a controlled substance to a degree rendering the person incapable of safe driving; the voluntariness of the intoxication is not an element the Commonwealth must prove. The court classified DUI as a strict or absolute liability offense, for which the legislature chose to omit a culpability requirement. Therefore, the voluntary act requirement of Section 301 of the Crimes Code is inapplicable, as Section 305 exempts such statutory offenses. Placing the burden on the defendant is also justified because the information regarding intoxication is peculiarly within the defendant's knowledge and control.



Analysis:

This decision solidifies the principle that DUI is a strict liability offense in Pennsylvania, meaning the prosecution does not need to prove any mental state (mens rea) regarding the act of becoming intoxicated. By placing the burden of proof for the affirmative defense of involuntary intoxication on the defendant, the court reinforces the legislature's power to create public welfare offenses where the act itself is sufficient for conviction. This ruling creates a significant procedural hurdle for defendants who claim they were involuntarily intoxicated, making the defense more difficult to successfully assert in DUI cases.

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