People v. Scott
1983 Cal. App. LEXIS 2122, 146 Cal. App. 3d 823, 194 Cal. Rptr. 633 (1983)
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Rule of Law:
A defendant's honest but mistaken belief, which negates the specific intent required for a crime, constitutes a valid mistake of fact defense if the belief stems from a delusion caused by involuntary intoxication.
Facts:
- Walter Stephen Scott attended a party and drank red punch from a punch bowl.
- Other guests who drank the punch began behaving bizarrely, hallucinating, and vomiting.
- Scott's brother observed him with dilated pupils and acting uncoordinated, and during the car ride home, Scott hallucinated seeing a 'fireball in the sky' and believed he could fly.
- Two days later, Scott experienced a recurrence of these feelings and began to hallucinate that he was a secret agent for the CIA being pursued.
- While driving with his mother-in-law, Scott stated the CIA was after him and he needed to get to the police for help.
- After his own car overheated and stopped, Scott, still under the delusion he was a secret agent on a mission, attempted to commandeer several vehicles.
- He first knocked a boy, Robert Briggs, off his motorbike and tried to start it.
- He then jumped onto a forklift at a lumber yard operated by Christopher Bell, declaring he needed it for 'police business.'
- Finally, he jumped into a truck belonging to Cecil Endeman and asked how to start it, stating 'I'm with the CIA and I need to use the car.'
Procedural Posture:
- Walter Stephen Scott was charged by information in the Superior Court (trial court) with attempted robbery and two counts of attempted unlawful taking of a vehicle.
- Scott entered pleas of not guilty and not guilty by reason of insanity, waived his right to a jury trial, and agreed to a bench trial.
- The trial court dismissed the attempted robbery charge.
- The trial court found Scott guilty of the two counts of attempted unlawful taking of a vehicle.
- After the verdict, Scott withdrew his insanity plea in exchange for an agreement that he would receive summary probation.
- Scott (appellant) appealed the judgment of conviction to the California Court of Appeal (intermediate appellate court).
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Issue:
Does a defendant's delusion that they are a government agent acting under the necessity of saving a life, a belief caused by involuntary intoxication, constitute a mistake of fact that negates the specific intent required for attempted unlawful taking of a vehicle?
Opinions:
Majority - Kaufman, J.
No. A defendant's delusion caused by involuntary intoxication constitutes a valid mistake of fact defense that negates the specific intent required for the crime. The court evaluates the defendant's guilt as if the facts were as the defendant perceived them. Here, Scott acted under the mistaken belief that he was a secret agent acting to save his own life or the President's. If these perceived facts were true, his actions would have been legally justified under the doctrine of necessity. The court held that while the mistake of fact was irrational, it was 'reasonable under the circumstances' because the delusion was caused by involuntary intoxication. This distinguishes the case from voluntary intoxication, where such a mistake would not be considered reasonable.
Analysis:
This decision solidifies the mistake of fact defense under California Penal Code § 26 in the context of involuntary intoxication. It establishes that a delusion caused by involuntary intoxication can render an otherwise irrational mistake of fact legally 'reasonable,' thereby negating specific criminal intent. The case creates a critical distinction between the legal effects of voluntary and involuntary intoxication, affirming that only the latter can support a reasonable mistake of fact defense based on delusion. This precedent directs lower courts to analyze the defendant's conduct based on their perceived reality, provided that reality was distorted by factors beyond their control.
