State v. Ellis
1996 WL 348101, 677 So. 2d 617 (1996)
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Rule of Law:
Voluntary intoxication is an affirmative defense for which the defendant bears the burden of proof. A defendant's purposeful actions before, during, and after an offense can serve as sufficient circumstantial evidence for a jury to infer specific intent, even if the defendant was severely intoxicated.
Facts:
- On the evening of July 29, 1994, Randy Ellis and his cousin, Donnie Manning, had been drinking for most of the day.
- The two men engaged in a verbal argument that escalated into a physical fight.
- Ellis's brother, Clinton Ellis Jr., intervened and separated the two men.
- After being separated, Ellis ran toward his mother's apartment.
- Ellis returned from the direction of the apartment, chased after the unarmed Manning, and shouted, "I'll kill you, m f , I'll kill you."
- Manning tripped and fell while attempting to flee.
- Ellis caught up to Manning, grabbed him from behind, and stabbed him once in the chest.
- Shortly after the stabbing, police officers spotted Ellis crouched and walking between buildings in an apparent attempt to leave the scene.
Procedural Posture:
- Randy Ellis was indicted by the state of Louisiana for the second-degree murder of Donnie Manning.
- Following an examination by a sanity commission, the trial court determined Ellis was competent to proceed to trial.
- Ellis was tried before a 12-member jury in the District Court and was found guilty as charged.
- The District Court imposed the mandatory sentence of life in prison at hard labor without benefit of parole, probation, or suspension of sentence.
- Ellis, as Defendant-Appellant, appealed his conviction to the Court of Appeal of Louisiana, Second Circuit.
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Issue:
Does a defendant's claim of severe intoxication and an alcoholic 'blackout' defeat a finding of specific intent for second-degree murder when circumstantial evidence shows purposeful actions like retrieving a weapon, pursuing the victim, and making verbal threats?
Opinions:
Majority - Norris, J.
No. A defendant's claim of severe intoxication does not defeat a finding of specific intent for second-degree murder when the defendant’s actions demonstrate a purposeful design to commit the crime. Specific intent is a state of mind that can be inferred from the circumstances of the offense and the defendant's actions. While voluntary intoxication can be a defense if it precludes the presence of specific intent, the defendant carries the burden of proving this condition. In this case, Ellis's actions—fighting with the victim, retreating to apparently arm himself with a knife, returning to chase the victim, threatening to kill him, and fatally stabbing him—are sufficient for a rational jury to infer that he had the specific intent to kill or inflict great bodily harm. Although Ellis presented expert testimony that he experienced an 'intoxicated blackout,' the jury was entitled to weigh this against the state's expert and the officers' testimony and conclude that despite his intoxication, Ellis was capable of purposeful action and possessed the requisite intent.
Analysis:
This case reinforces the high evidentiary burden a defendant faces when asserting a voluntary intoxication defense to a specific intent crime. It affirms that a defendant's conduct can provide powerful circumstantial evidence of intent that outweighs even expert testimony regarding intoxication-induced 'blackouts' or amnesia. The decision gives significant deference to the jury's role as the fact-finder, particularly in weighing conflicting expert opinions and inferring a defendant's mental state from their actions. This precedent makes it difficult for defendants to negate specific intent based on intoxication alone if their actions appear methodical or goal-oriented.
