Paul J. Heideman v. United States
259 F.2d 943 (1958)
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Rule of Law:
A defendant is entitled to a jury instruction on the defense of intoxication for a specific intent crime only if sufficient evidence is introduced for a reasonable person to entertain a doubt that the defendant was capable of forming the necessary intent. Additionally, a confession obtained shortly after arrest is admissible if the delay before arraignment was brief and used for necessary administrative procedures and appropriate, non-coercive questioning.
Facts:
- Appellant Heideman, a sailor, and his co-defendant Brennan were drinking whiskey on the evening of October 24, 1957.
- Before hailing a taxicab, Heideman prepared a weapon by filling a sock with gravel.
- Heideman and Brennan boarded the cab, with Brennan sitting in the front passenger seat and Heideman in the rear seat.
- During the ride, Heideman struck the cab driver over the head with the sock filled with gravel.
- Brennan pulled the emergency brake, after which the two men took the driver's wallet and fled the scene.
- The next day, Detective Conley investigated the crime and identified Heideman and Brennan as suspects.
- At approximately 3:00 p.m., Armed Services police brought Heideman and Brennan to police headquarters.
- After his co-defendant confessed, Heideman also confessed to the robbery between 3:30 and 3:45 p.m.
Procedural Posture:
- Appellant, Heideman, was tried for robbery in the trial court.
- At trial, Heideman's oral confession was admitted into evidence over his objection.
- The trial court refused to give the jury a requested instruction on intoxication as a defense that could negate the specific intent required for robbery.
- The jury convicted Heideman of robbery.
- Heideman appealed his conviction to the United States Court of Appeals for the District of Columbia Circuit.
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Issue:
Is a defendant charged with robbery entitled to a jury instruction on the defense of intoxication, which could negate the required specific intent, when the evidence of intoxication is contradicted and the defendant's actions demonstrate advance preparation and logical execution of the crime?
Opinions:
Majority - Burger, Circuit Judge
No. A defendant is not entitled to an instruction on the defense of intoxication where the evidence is insufficient to permit a reasonable person to doubt his capacity to form the specific intent required for the crime. Robbery is a specific intent crime, and while intoxication may be relevant, an instruction is only necessary when the evidentiary groundwork is adequately laid. In this case, the evidence of intoxication was weak and contradicted by testimony that the defendants were not drunk. More importantly, Heideman's actions—including the careful advance preparation of a weapon, the strategic seating arrangement in the cab, the coordinated attack, and the subsequent flight—demonstrate a mind working logically and rationally towards a criminal purpose, negating any claim that he was too intoxicated to form the intent to rob. Furthermore, the confession was admissible because the brief period between arrest and arraignment did not constitute an "unnecessary delay" under Mallory v. United States, as it was used for legitimate and necessary police administrative procedures and brief, non-coercive interrogation.
Dissenting - Bazelon, Circuit Judge
Yes. The defendant was entitled to an instruction on intoxication because the conflicting evidence presented a question of fact for the jury to decide. Co-defendant Brennan testified that Heideman was drunk, while the victim testified he was not; this conflicting testimony created an issue of fact as to whether Heideman's drunkenness negated his ability to form the specific intent to rob. It is the jury's role, not the court's, to weigh this evidence and make a determination under a proper instruction. The trial judge committed reversible error by refusing the instruction and telling the jury that intoxication was no defense. Additionally, the confession should have been suppressed under Mallory because the police took the defendants to the station for the purpose of interrogation before bringing them to a magistrate, thereby violating the principle that a suspect must be advised of their rights by a judicial officer before police interrogation can occur.
Analysis:
This case clarifies the evidentiary threshold required for a defendant to receive a jury instruction on the defense of intoxication for specific intent crimes. It establishes that courts can deny such an instruction if evidence of the defendant's purposeful, planned, and rational conduct during the crime outweighs conflicting or weak testimony about their level of intoxication. The decision also refines the 'unnecessary delay' rule from Mallory, creating a practical allowance for brief, non-coercive questioning and administrative processing immediately following an arrest, so long as it does not become a prolonged 'grilling' session designed solely to extract a confession before arraignment.
