State v. Knowles
1992 WL 72672, 598 So. 2d 430 (1992)
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Rule of Law:
Voluntary intoxication from anabolic steroid use does not negate the specific intent required for second-degree murder, nor does it establish legal insanity, when the defendant's purposeful actions during and after the crime demonstrate an intent to kill and an ability to distinguish between right and wrong.
Facts:
- Ricky D. Knowles, 18, and his 14-year-old second cousin, the victim, were involved in a sexual relationship.
- Knowles was a 210-pound weightlifter who, for approximately nine months prior to the incident, had been taking large doses of anabolic steroids, leading to a marked increase in aggressive behavior.
- On the afternoon of April 8, 1990, the victim went to Knowles's home, where they were alone.
- After they had sex, an argument ensued over Knowles's broken promise to take the victim to a party.
- According to Knowles, the victim grabbed a knife from the kitchen; he disarmed her, and after she began beating him, he stabbed her.
- Knowles stabbed the victim multiple times, resulting in five major stab wounds—four of which were in a tight pattern around her heart—and several other minor puncture wounds.
- Following the stabbing, Knowles placed the victim's body in a trash can, dragged it across nearby railroad tracks, and hid it underneath a raised building.
- Knowles then returned to his home, attempted to clean the blood, and intentionally cut himself to create a cover story that the blood was his own.
Procedural Posture:
- Ricky D. Knowles was arrested and charged with second degree murder.
- The defendant filed a motion for a mental examination regarding his competency and sanity at the time of the offense.
- A bill of indictment was filed, officially charging Knowles with second degree murder.
- The district court (trial court) found Knowles competent to stand trial.
- Knowles initially pled not guilty, then changed his plea to not guilty and not guilty by reason of insanity.
- Following a jury trial, Knowles was convicted of second degree murder.
- The trial court sentenced Knowles to the mandatory term of life imprisonment at hard labor.
- Knowles (appellant) appealed his conviction and sentence to the Court of Appeal of Louisiana, Second Circuit, against the State of Louisiana (appellee).
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Issue:
Does a defendant's voluntary intoxication from anabolic steroid abuse negate the specific intent required for a second-degree murder conviction when evidence, such as the strategic placement of wounds and subsequent concealment of the crime, suggests purposeful action and an ability to distinguish right from wrong?
Opinions:
Majority - Sexton, J.
No, a defendant's voluntary intoxication from anabolic steroid abuse does not negate the specific intent required for second-degree murder when other evidence demonstrates purposeful action. Specific intent can be inferred from the circumstances of the crime and the defendant's actions. The court found that the number and placement of the victim's wounds, concentrated in a 'killing zone' around the heart, were strong evidence of a specific intent to kill, rather than acts committed in an uncontrollable rage. Furthermore, Louisiana law does not recognize the doctrine of diminished capacity, meaning a mental defect short of legal insanity cannot reduce the degree of a crime. The defendant's actions after the murder—hiding the body, cleaning the crime scene, and fabricating a cover story by intentionally cutting himself—were powerful evidence that he was capable of distinguishing between right and wrong and was therefore not legally insane at the time of the offense. The jury was entitled to weigh the conflicting expert testimony on Knowles's mental state and conclude that he failed to prove insanity by a preponderance of the evidence.
Analysis:
This decision solidifies that a defense based on 'roid rage' or other forms of voluntary intoxication faces a very high evidentiary burden in Louisiana. It reinforces the state's strict rejection of the diminished capacity doctrine, affirming that only a complete inability to distinguish right from wrong can support an insanity defense. The court's heavy reliance on the defendant's post-offense conduct—concealment and creating a cover story—establishes strong precedent for using such actions to prove both specific intent and legal sanity, providing a clear prosecutorial pathway in cases with similar defenses.
