People v. Langworthy
331 N.W.2d 171, 416 Mich. 630 (1982)
Rule of Law:
Voluntary intoxication is not a defense to general-intent crimes. First-degree criminal sexual conduct and second-degree murder are general-intent crimes because their requisite mental states do not require a specific intent to achieve a further consequence beyond the criminal act itself.
Facts:
- On November 5, 1976, defendant Langworthy was with two other men consuming alcohol and drugs.
- William Wedge, who was also intoxicated, joined the group and made comments that irritated Langworthy.
- After Wedge passed out, Langworthy discussed robbing him with the others.
- Langworthy then suggested they "blow him away," retrieved a rifle, and shot Wedge twice, killing him.
- In a separate incident on October 30, 1978, defendant Lundy was sniffing glue and drinking alcohol.
- Lundy used a knife to threaten his adult sister.
- Lundy then raped his sister, which involved three acts of sexual penetration.
Procedural Posture:
- Defendant Lundy was convicted of first-degree criminal sexual conduct in a Michigan trial court following a bench trial where the court ruled the crime was one of general intent.
- Defendant Langworthy was convicted of second-degree murder in a Michigan trial court following a bench trial where the court also rejected the voluntary intoxication defense.
- Lundy, as appellant, appealed to the Michigan Court of Appeals (intermediate appellate court), which affirmed his conviction.
- Langworthy, as appellant, appealed to the Michigan Court of Appeals (intermediate appellate court), which also affirmed his conviction.
- Both defendants, as appellants, were granted leave to appeal to the Michigan Supreme Court, where their cases were consolidated.
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Issue:
Does the defense of voluntary intoxication apply to the crimes of first-degree criminal sexual conduct and second-degree murder by classifying them as specific-intent crimes under Michigan law?
Opinions:
Majority - Fitzgerald, C.J.
No, the defense of voluntary intoxication does not apply because first-degree criminal sexual conduct and second-degree murder are general-intent crimes. The court acknowledged the logical flaws in the general/specific intent dichotomy but declined to abolish this long-standing common-law rule, deferring to the legislature. Regarding first-degree criminal sexual conduct, the court reasoned that its predecessor crime, rape, was historically a general-intent crime, and the legislature did not insert any language requiring specific intent into the new statute. For second-degree murder, the requisite mental state of 'malice' can be satisfied by an intent to kill, an intent to do great bodily harm, or a wanton and willful disregard for the likelihood of causing death. Because malice can be established by the general intent of wanton and willful disregard, a specific intent to kill is not required, and public policy precludes allowing intoxication to negate this form of malice.
Dissenting - Levin, J.
Yes, the defense of voluntary intoxication should apply because both offenses should be treated as specific-intent crimes. For second-degree murder, the dissent argues it is nearly always prosecuted based on an intent to kill or do great bodily harm, both of which are specific intents; classifying the crime based on the rarely used 'wanton and willful disregard' theory is illogical. In Langworthy's case, the judge made a specific finding of 'intending to kill him.' For first-degree criminal sexual conduct, the statute requires specific intent for the lesser act of 'sexual contact,' making it anomalous and inconsistent not to require a specific intent for the more serious act of 'sexual penetration.' Therefore, the trial courts erred by refusing to consider the intoxication defense for either defendant.
Analysis:
This decision reaffirms Michigan's adherence to the traditional, though often criticized, specific versus general intent framework for the voluntary intoxication defense. It solidifies the legal status of second-degree murder and the newly enacted first-degree criminal sexual conduct as general-intent crimes, thereby limiting a defendant's ability to argue that intoxication negated the required criminal mindset. By explicitly deferring to the legislature to reform this area of law, the court signals that changes to this common-law doctrine must come from statutory enactment rather than judicial reinterpretation, cementing the existing precedent for future cases.
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