State v. Hurst
1992 WL 275424, 606 So. 2d 965 (1992)
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Rule of Law:
Voluntary intoxication is not a defense to the crime of aggravated rape because it is a general intent crime under Louisiana law. The act of sexual intercourse itself does not constitute "special knowledge" that could be negated by intoxication under La.R.S. 14:15(2).
Facts:
- Walter Wayne Hurst, Jr. lured a nine-year-old girl to his apartment with the promise of giving her a bicycle.
- Hurst then separated the girl from her friend by suggesting they play a game of hide-and-seek.
- When the victim's brothers came to Hurst's apartment looking for her, he told them she was not there and instructed the victim to hide in a closet.
- After the brothers left and returned, Hurst took the victim to his truck and forced her to hide behind the seat.
- Hurst drove the victim to a dead-end road.
- At this location, Hurst instructed the victim to undress and then raped her.
- During the assault, Hurst threatened the victim, and she bit him.
- After the rape, Hurst drove the victim to a location near her home, dropped her off, and warned her not to tell anyone.
Procedural Posture:
- Walter Wayne Hurst, Jr. was charged with aggravated rape by a grand jury indictment.
- Following a jury trial in the state trial court, Hurst was found guilty as charged.
- Hurst, as the appellant, appealed his conviction to the Court of Appeal of Louisiana, Third Circuit.
- The State of Louisiana is the appellee in this appeal.
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Issue:
Does a defendant's voluntary intoxication and alleged brain dysfunction preclude the presence of the requisite general criminal intent or "special knowledge" for the crime of aggravated rape, thereby making evidence of such conditions admissible as a defense?
Opinions:
Majority - Marcantel, J. Pro Tem.
No. A defendant's voluntary intoxication is not a defense to the general intent crime of aggravated rape, and thus evidence of it is not admissible. The Louisiana statute for aggravated rape, La.R.S. 14:42, does not require specific intent, which makes it a general intent crime. The intoxication defense provided in La.R.S. 14:15 is only applicable to specific intent crimes or crimes requiring 'special knowledge.' The court rejected Hurst's argument that the act of sexual intercourse itself constitutes 'special knowledge,' as there is no legal authority for this interpretation. Furthermore, Louisiana law does not recognize the doctrine of diminished capacity, and the only relevant mental defense is the insanity defense (inability to distinguish right from wrong), which Hurst did not plead. Therefore, the trial court properly excluded the proposed testimony regarding Hurst's intoxicated state and mental condition.
Analysis:
This decision reaffirms that aggravated rape is a general intent crime in Louisiana, thereby precluding the use of a voluntary intoxication defense. By narrowly interpreting the 'special knowledge' exception, the court closes a potential loophole for defendants and solidifies the state's strict stance against defenses based on diminished capacity short of legal insanity. This precedent provides clear guidance to trial courts to exclude such evidence, reinforcing the principle that a defendant's intoxicated state does not negate the criminal responsibility for such a serious offense.
