Miller v. Florida
805 So.2d 885 (2001)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The defense of involuntary intoxication is not limited to establishing legal insanity; it may also be used to show that a defendant was incapable of forming the specific intent required to commit a specific intent crime.
Facts:
- John Robert Miller, a heroin user, sought treatment at a Neuraad clinic for opiate detoxification.
- At the clinic, he was administered intense doses of numerous toxic drugs and was sedated with anesthesia.
- Approximately 27 hours later, Miller was released from the clinic while still under the influence of significant amounts of medication and with prescriptions for more.
- Within three hours of his release, Miller went to his former methadone clinic, the Parental Awareness and Responsibility (PAR) clinic.
- Finding the PAR clinic closed, Miller shot the lock off a gate, fired several shots into the building, broke a window, and climbed inside.
- He later surrendered to police who entered the building.
Procedural Posture:
- John Robert Miller was charged by the State of Florida with burglary with a firearm, shooting into a building, and discharging a firearm in public.
- At trial in the state trial court, Miller raised the defenses of insanity and intoxication based on medication he received during a medical procedure.
- The trial court rejected Miller's proposed jury instruction on involuntary intoxication and gave its own instruction, which limited the defense to proving insanity.
- The jury convicted Miller on all counts.
- Miller (Appellant) appealed his convictions for armed burglary and shooting into a building to the District Court of Appeal of Florida, Second District, with the State of Florida as the Appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a jury instruction that limits the defense of involuntary intoxication to only proving legal insanity, and precludes its use to negate the specific intent for a crime, constitute a misstatement of the law?
Opinions:
Majority - Davis, Judge
Yes. A jury instruction that limits the defense of involuntary intoxication to proving legal insanity is an erroneous statement of the law because involuntary intoxication can also serve as a defense to a specific intent crime. The court reasoned that there is a crucial distinction between an insanity defense, which results in a complete acquittal, and an intoxication defense, which only negates the specific intent element of certain crimes. While involuntary intoxication can be the basis for an insanity defense, it is not the exclusive way to apply the defense. The court found it illogical that voluntary intoxication could excuse a defendant from a specific intent crime while involuntary intoxication could not. Citing the Washington Supreme Court, the opinion states that if a defendant is too intoxicated to form the requisite intent, it is irrelevant whether that intoxication was voluntary or involuntary, as the State must prove the defendant's state of mind beyond a reasonable doubt.
Analysis:
This decision clarifies that involuntary intoxication operates as a dual-purpose defense in Florida. It can support a traditional insanity defense if the intoxication prevents the defendant from knowing right from wrong. More significantly, it also establishes that involuntary intoxication can function like the traditional voluntary intoxication defense (prior to its statutory abolishment) by negating the mens rea for specific intent crimes. This prevents an anomalous situation where a defendant who becomes intoxicated through no fault of their own has fewer legal defenses than one who chooses to become intoxicated. The ruling provides crucial guidance for trial courts on how to properly instruct juries when evidence of involuntary intoxication is presented in cases involving specific intent crimes.
Unlock the full brief for Miller v. Florida