Commonwealth v. Smith
831 A.2d 636 (2003)
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Rule of Law:
Intoxication resulting from the voluntary consumption of alcohol combined with a prescribed medication is not considered 'involuntary' for the purposes of a criminal defense, even if the defendant was unaware of the synergistic effect. To assert an involuntary intoxication defense based on a drug-alcohol interaction, a defendant must provide expert testimony establishing that the combination is capable of causing the alleged intoxication.
Facts:
- Karen Smith was prescribed and wore a 'duragesic' patch for pain.
- On March 29, 2002, Smith consumed beer while wearing the patch.
- Smith admitted that she did not read the directions or warnings for the patch.
- A police officer observed Smith driving her truck completely in the oncoming lane of traffic for one-tenth of a mile.
- When stopped, the officer noted Smith's eyes were glassy and bloodshot, she emanated a strong odor of alcohol, and she stumbled and staggered.
- Smith admitted to the officer that she had been drinking beer earlier in the evening.
- Smith failed three field sobriety tests administered by the officer.
Procedural Posture:
- Karen Smith was arrested and charged with driving under the influence (DUI).
- A bench trial was held in the Court of Common Pleas of Blair County (trial court).
- At trial, Smith argued the affirmative defense of involuntary intoxication but offered no expert testimony to support her claim.
- The trial court judge found Smith guilty and imposed a sentence of 48 hours to 18 months' incarceration.
- Smith filed a post-sentence motion in arrest of judgment, which the trial court denied.
- Smith (Appellant) then appealed the judgment of sentence to the Superior Court of Pennsylvania (an intermediate appellate court).
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Issue:
Does the affirmative defense of involuntary intoxication apply to a charge of driving under the influence (DUI) when a defendant voluntarily consumes alcohol while using a prescribed medication, without knowledge of the medication's potential to heighten the alcohol's effects?
Opinions:
Majority - Orie Melvin, J.
No, the defense of involuntary intoxication does not apply under these circumstances. The court reasoned that Smith's intoxication was 'self-induced' under the Model Penal Code's definition because she knowingly introduced alcohol into her body, a substance she should have known causes intoxication. The voluntary act of consuming alcohol precludes the defense, even if the resulting level of intoxication was unexpectedly heightened by a prescribed medication. Citing precedent from Commonwealth v. Todaro and Commonwealth v. Hicks, the court affirmed that combining alcohol with medication without knowledge of a synergistic effect does not render the intoxication involuntary. Furthermore, even if the defense were cognizable, Smith failed to meet her evidentiary burden. She was required to prove the defense by a preponderance of the evidence, which at a minimum necessitates expert testimony to establish that the drug-alcohol combination is capable of causing the alleged effect. Smith's self-serving testimony was insufficient to establish the factual foundation for her defense.
Analysis:
This decision significantly clarifies the scope of the involuntary intoxication defense in Pennsylvania, particularly in cases involving the common scenario of mixing alcohol with prescription drugs. By aligning with the Model Penal Code's definition of 'self-induced' intoxication, the court establishes that the voluntary act of drinking alcohol is the key factor, making the resulting intoxication culpable regardless of unforeseen drug interactions. The ruling creates a high evidentiary bar for defendants, requiring expert testimony to substantiate claims of synergistic effects, which prevents speculative defenses and strengthens the Commonwealth's position in DUI prosecutions involving prescription medication. This makes it substantially more difficult for defendants to use ignorance of a drug's side effects as a complete defense to a DUI charge.
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