State v. Cooper
529 P.2d 231, 1974 Ariz. LEXIS 431, 111 Ariz. 332 (1974)
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Rule of Law:
A temporary mental incapacity caused solely by the voluntary use of drugs or alcohol does not constitute a valid basis for the insanity defense; instead, it is treated as voluntary intoxication, which may only be used to negate specific intent.
Facts:
- Eugene Raymond Cooper had been voluntarily taking amphetamines for several days.
- After being reported for reckless driving, Cooper engaged in a high-speed chase with a police officer.
- During the pursuit, Cooper shot and wounded the officer.
- Shortly thereafter, Cooper kidnapped a man from a parking lot at gunpoint.
- The kidnap victim eventually wrestled the gun away from Cooper, causing the car to crash.
- Court-appointed psychiatrists and psychologists testified that without the voluntary drug use, Cooper would have been sane.
- The experts described Cooper's mental state at the time of the offenses as 'toxic psychosis' or an 'acute drug induced psychotic episode.'
Procedural Posture:
- Eugene Raymond Cooper was charged in a trial court with kidnapping and assault with a deadly weapon.
- At the defense's request, the trial court ordered a mental competency examination.
- Following a hearing, the trial court found Cooper competent to stand trial.
- The defense gave notice of its intent to raise the insanity defense.
- At trial, the court heard expert testimony from a psychiatrist and psychologist regarding Cooper's mental state.
- The trial court ruled the evidence was insufficient to raise the issue of sanity and refused to instruct the jury on the insanity defense.
- The jury convicted Cooper on both counts.
- Cooper (appellant) appealed his conviction to the Supreme Court of Arizona.
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Issue:
Does a temporary episode of mental incapacity, described as 'toxic psychosis,' caused by a defendant's voluntary use of drugs, constitute a valid basis for the insanity defense?
Opinions:
Majority - Holohan, Justice
No. A temporary episode of mental incapacity caused by the voluntary use of drugs does not constitute a valid basis for the insanity defense. The law distinguishes between an existing state of mental illness and a temporary mental incapacity caused by voluntary intoxication. While the defense of insanity is available for the former, even if aggravated by drug use, it is not available for the latter. The court reasoned that Cooper's condition was not a result of an underlying mental disease but was an 'artificially produced state of mind brought on by his own hand at his own choice.' Therefore, his condition is properly considered voluntary intoxication, which is not a complete defense to a crime, and the defendant did not meet the burden to overcome the presumption of sanity.
Analysis:
This decision clarifies the boundary between the insanity defense and the defense of voluntary intoxication in Arizona. It establishes that a defendant cannot successfully invoke the M'Naghten rule for insanity if the mental defect is a temporary condition created solely by their own choice to consume drugs or alcohol. This prevents the expansion of the insanity defense to cases of self-induced psychosis, reinforcing the legal principle that individuals are responsible for the consequences of their voluntary actions. The ruling limits defendants in such situations to arguing only that their intoxication negated the specific intent required for the crime, rather than allowing a complete excuse for their conduct.
