State v. Anderson
1992 WL 163424, 603 So.2d 780 (1992)
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Rule of Law:
Voluntary intoxication is a defense to a specific intent crime, such as simple burglary, only if the defendant's condition was so severe that it precluded the formation of the required criminal intent. When this defense is raised, the state bears the burden of proving beyond a reasonable doubt that the defendant possessed the necessary specific intent despite their intoxication.
Facts:
- On July 14, 1990, Officers Freddie Williams and Milton Wolfe were working as security at a wedding reception.
- A witness informed the officers that someone was inside Officer Wolfe's personal vehicle, which was parked outside.
- The officers ran to the vehicle and found Vincent Paul Anderson in the front seat.
- Officer Wolfe observed that the faceplate of his car stereo and several screws were missing.
- A subsequent search of Anderson revealed the missing stereo knobs in his pocket.
- Officer Wolfe testified that Anderson did not have permission to be in the vehicle.
- Multiple officers testified that while Anderson smelled of alcohol, he was coherent, understood what was happening, and could walk without stumbling.
Procedural Posture:
- The State of Louisiana charged Vincent Paul Anderson by bill of information with simple burglary.
- Anderson pled not guilty and was tried by a jury in the trial court.
- The jury returned a verdict of guilty as charged.
- The trial court subsequently adjudicated Anderson a second felony habitual offender.
- The trial court sentenced Anderson to twenty years at hard labor.
- Anderson appealed his conviction and sentence to the Court of Appeal of Louisiana, First Circuit.
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Issue:
Does a defendant's voluntary intoxication negate the specific intent required for a simple burglary conviction when evidence shows the defendant, despite having consumed alcohol, was coherent, able to walk steadily, and performed actions indicating a clear purpose to commit theft?
Opinions:
Majority - Crain, Judge
No, the defendant's voluntary intoxication does not negate the specific intent required for a simple burglary conviction under these circumstances. To be found guilty of simple burglary, the prosecution must prove the defendant had the specific intent to commit a felony or theft at the time of the unauthorized entry. While voluntary intoxication can be a defense if it prevents the formation of this intent, the State can overcome it by proving the mental element was present beyond a reasonable doubt. In this case, Anderson's actions—being inside the vehicle, dismantling the stereo, and possessing the missing parts—constituted strong circumstantial evidence of his intent to steal. Testimony from officers that he was coherent and in control of his motor functions, despite having been drinking, was sufficient for a rational jury to conclude that his intoxication did not preclude him from forming the specific intent required for burglary.
Analysis:
This decision reinforces the high evidentiary standard required for a defendant to successfully use the voluntary intoxication defense for a specific intent crime. It clarifies that mere evidence of alcohol consumption is insufficient; the defense fails if the prosecution can present evidence that the defendant remained capable of purposeful action. The ruling demonstrates that courts will heavily weigh circumstantial evidence of intent, such as the defendant's actions during the crime, and objective observations of the defendant's physical and mental state. This precedent makes it more difficult for defendants to claim a lack of specific intent due to intoxication unless they can show their impairment was truly debilitating and prevented rational thought.
