State v. Cameron
514 A.2d 1302 (1986)
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Rule of Law:
Voluntary intoxication is a defense to a crime requiring a 'purposeful' or 'knowing' mental state only if the intoxication is so severe that it results in a 'prostration of faculties,' rendering the defendant incapable of forming the requisite intent. Merely showing a defendant was drinking and acting bizarrely is insufficient to require a jury instruction on the defense.
Facts:
- Michele Cameron approached a group of men, including Joseph McKinney, who were playing cards in a vacant lot.
- Cameron disrupted the game, and when the men moved their card table to a new location, she followed them and overturned the table.
- Shortly thereafter, Cameron attacked McKinney with a broken bottle, causing a severe hand injury that required 36 stitches and resulted in permanent injury.
- Cameron had been sharing a quart of wine with others on the lot, and approximately one pint was consumed in total.
- When police arrived, Cameron threw a bottle at their vehicle, shouted obscenities, and physically fought with the officers.
- At trial, Cameron testified that she acted in self-defense to ward off a sexual attack by McKinney and others, and she recalled the events of the incident with explicit detail.
Procedural Posture:
- Michele Cameron was prosecuted by the State in a New Jersey trial court.
- A jury convicted Cameron of second degree aggravated assault, possession of a weapon for an unlawful purpose, and fourth degree resisting arrest.
- Cameron, as appellant, appealed her convictions to the New Jersey Appellate Division, an intermediate appellate court.
- The Appellate Division reversed Cameron's convictions, holding that the trial court erred by refusing to instruct the jury on the intoxication defense.
- The State, as petitioner, successfully petitioned the Supreme Court of New Jersey, the state's highest court, for certification to review the Appellate Division's decision.
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Issue:
Does a defendant's claim of feeling 'very intoxicated,' coupled with testimony that she was 'drunk' and acting bizarrely, provide sufficient evidence to require a trial court to instruct a jury on the defense of voluntary intoxication?
Opinions:
Majority - Clifford, J.
No. A defendant's claim of intoxication does not warrant a jury instruction unless the evidence demonstrates a 'prostration of faculties' so great that the defendant was incapable of forming the requisite purposeful or knowing intent. The New Jersey Code of Criminal Justice allows an intoxication defense if it negatives an element of the offense, which applies to crimes requiring purposeful or knowing conduct. However, the standard for this defense is extremely high and requires more than just evidence of drinking, bizarre behavior, or conclusory statements about being 'drunk.' In this case, although Cameron was drinking and acted violently, her detailed recall of the events and her claim of self-defense demonstrate that her faculties were not so prostrated as to render her incapable of forming a purpose. Therefore, the evidence was insufficient to require the trial court to give the intoxication instruction.
Analysis:
This decision clarifies the high evidentiary threshold required for the voluntary intoxication defense under the New Jersey Code of Criminal Justice. It firmly establishes the 'prostration of faculties' standard, moving away from the old, confusing 'specific vs. general intent' dichotomy. The case serves as a critical guide for trial courts in determining when the evidence of intoxication is sufficient to present the defense to a jury, thereby preventing defendants from using evidence of mere drunkenness to excuse purposeful criminal acts. It emphasizes that a defendant's detailed recall of events can significantly undermine an intoxication defense claim.
