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People v. Hood

Supreme Court of California
1 Cal.3d 444, 462 P.2d 370, 82 Cal. Rptr. 618 (1969)
ELI5:

Rule of Law:

Assault with a deadly weapon is a general intent crime, meaning evidence of a defendant's voluntary intoxication is inadmissible to negate the criminal intent required for the offense. A distinction is made between general intent crimes, where intoxication is no defense, and specific intent crimes, which require an intent to achieve a further consequence and where intoxication may be a valid defense.


Facts:

  • David Keith Hood, his brother, and a friend, after drinking for several hours, went to the home of Hood's ex-girlfriend, Susan Bueno.
  • Hood forced his way into the house and proceeded to hit and kick Bueno.
  • A neighbor heard Bueno's screams and called the police.
  • Officers Alfred Elia and Donald Kemper responded to the call, and Bueno identified Hood and his companions as her assailants.
  • When Officer Elia began questioning the men, Hood became belligerent and directed a stream of obscenities at the officer.
  • As Officer Elia attempted to place Hood under arrest, Hood swung at him with his fist, initiating a physical struggle.
  • During the struggle, Hood gained control of Officer Elia's service revolver.
  • Hood shot Officer Elia twice, hitting him once in each leg.

Procedural Posture:

  • An indictment in a California trial court charged David Keith Hood with assault with a deadly weapon upon a peace officer (Count I), battery upon a peace officer (Count II), and assault with intent to murder (Count III).
  • A jury found Hood guilty on Counts I and III, and acquitted him on Count II.
  • The trial court entered a judgment on the jury's verdicts.
  • Hood, the defendant-appellant, appealed the judgment to the Supreme Court of California.

Locked

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Issue:

Is assault with a deadly weapon a specific intent crime for which evidence of voluntary intoxication is admissible to negate the required criminal intent?


Opinions:

Majority - Traynor, C. J.

No. Assault with a deadly weapon is a general intent crime, and evidence of voluntary intoxication is therefore irrelevant to negate the required intent. The court acknowledged the historical difficulty in defining and applying the distinction between specific and general intent crimes, noting it often rests on a linguistic, rather than substantive, basis. The court reasoned that for assault, the distinction is 'chimerical,' as the requisite intent could be described under either category. Therefore, the decision must be based on policy considerations. A compelling policy is the effect of alcohol on human behavior, which often leads to the very type of impulsive, aggressive conduct that constitutes assault. It would be anomalous to allow intoxication to excuse a crime it so frequently precipitates. A person who is voluntarily intoxicated is still capable of forming the simple, goal-directed intent to strike another, even if their judgment is impaired. While intoxication can be used as a defense for crimes requiring a more complex, specific intent (e.g., intent to kill in an assault with intent to murder charge), it cannot be used to negate the general intent required for simple assault or assault with a deadly weapon. The court also held that the trial court committed prejudicial error by giving conflicting instructions on intoxication for the specific intent crime of assault with intent to murder, and by failing to instruct the jury on the lesser included offense of assault with a deadly weapon (not upon a peace officer).



Analysis:

This landmark decision clarifies the confusing distinction between specific and general intent crimes in California law, particularly regarding the defense of voluntary intoxication. By classifying assault as a general intent crime based on public policy, the court established that intoxication cannot be used to absolve a defendant of responsibility for such violent acts. This ruling prioritizes public safety and accountability over a rigid, and often illogical, application of the traditional intent framework. The case solidifies the principle that while intoxication may negate the mental state for complex crimes requiring a further objective, it does not excuse crimes involving simple, goal-directed aggression.

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