People v. Atkins
25 Cal. 4th 76, 18 P.3d 660, 104 Cal. Rptr. 2d 738 (2001)
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Rule of Law:
The crime of arson under California Penal Code § 451 is a general intent crime. Therefore, evidence of a defendant's voluntary intoxication is not admissible to negate the required mental state of willfully and maliciously setting fire to property.
Facts:
- Robert Nelson Atkins told his friends he hated Orville Figgs and was going to burn down Figgs's house.
- On September 27, 1997, Atkins and his brother spent much of the day drinking.
- They drove to the Ponderosa Sky Ranch canyon near Figgs's home, where they drank more for several hours.
- A friend later saw Atkins and described him as 'heavily intoxicated' and 'very agitated.'
- Atkins poured a gasoline and oil mixture on a pile of weeds in the canyon and lit it with a disposable lighter.
- The fire spread rapidly out of control, burning over two miles of forest land and coming within 150 feet of Figgs's house.
- Atkins later admitted to a fire marshall that he started the fire, claiming it was an accident and he meant no harm, but also acknowledged his family's 'hard feelings' toward the Figgs family.
- Atkins's wallet was found near the fire's origin.
Procedural Posture:
- The People charged Robert Nelson Atkins with arson of forest land in a California trial court.
- The trial court instructed the jury that arson is a general intent crime and that voluntary intoxication is not a defense.
- A jury found Atkins guilty of arson.
- Atkins, as appellant, appealed his conviction to the California Court of Appeal.
- The Court of Appeal, agreeing with Atkins, reversed the conviction, holding that the trial court erred because evidence of intoxication should have been admissible to negate the specific mental state required for arson.
- The People, as petitioner, sought review from the Supreme Court of California.
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Issue:
Is evidence of a defendant's voluntary intoxication admissible under California Penal Code § 22 to negate the mental state required for the crime of arson?
Opinions:
Majority - Chin, J.
No. Evidence of voluntary intoxication is inadmissible to negate the general criminal intent required for arson. The definition of arson as willfully and maliciously setting a fire does not require an intent to do a further act or achieve a future consequence, which is the definition of a specific intent crime established in People v. Hood. The court reasoned that the statutory language, using terms like 'willfully' and 'maliciously,' denotes general intent. The legislative history further supports this conclusion, as a prior version of the arson statute containing explicit specific intent language ('with intent to destroy it') was repealed in 1929. The court also found that, as a matter of policy, arson is an impulsive crime frequently linked to alcohol consumption, making it anomalous to allow intoxication as a defense, much like the crime of assault.
Concurring - Mosk, J.
I concur in the result. The decision to admit or exclude evidence of voluntary intoxication is ultimately based on policy, not on the technical definitions of general and specific intent. While arson's required mental state could be characterized as a specific intent (an intent to set a fire for the purpose of doing a wrongful act), it should be treated as a general intent crime for policy reasons. Because arson is so closely linked to voluntary intoxication in its commission, it would be anomalous to allow intoxication to serve as a defense.
Concurring - Brown, J.
I concur in the result. This case illustrates the confusion caused by this court's prior decision in People v. Mendoza, which I believe was wrongly decided. The Court of Appeal's erroneous decision was substantially bolstered by its reliance on Mendoza's flawed reasoning, which improperly transmuted a knowledge requirement into a specific intent. The majority's attempt to distinguish Mendoza will likely cause more confusion.
Analysis:
This decision resolves a conflict among the California Courts of Appeal by definitively classifying arson as a general intent crime. By doing so, the court prevents defendants from using evidence of their voluntary intoxication to negate the required mental state for arson. This holding strengthens the legal principle that intoxication does not excuse dangerous, impulsive acts and ensures that defendants cannot easily reduce an arson charge to the lesser crime of recklessly causing a fire simply by claiming they were drunk. The case solidifies the application of the Hood framework and reinforces the policy that individuals are held responsible for crimes frequently associated with intoxication.
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