State v. Vaughn
1977 S.C. LEXIS 391, 232 S.E.2d 328, 268 S.C. 119 (1977)
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Rule of Law:
Voluntary intoxication, where it has not produced permanent insanity, is not an excuse for or a defense to a crime, regardless of whether the crime requires a general or specific intent.
Facts:
- On or about August 21, 1975, the appellant entered the mobile home of two residents in Charleston.
- While inside the mobile home, an assault occurred.
- The appellant claimed to have been voluntarily intoxicated at the time of the incident.
- The appellant had a prior conviction in 1975 for the crimes of housebreaking and grand larceny.
Procedural Posture:
- The appellant was indicted in a state trial court for burglary and assault with intent to ravish.
- The appellant's pre-trial motion for a continuance was denied by the trial judge.
- A jury found the appellant guilty of the lesser included offenses of housebreaking and assault and battery of a high and aggravated nature.
- The trial judge sentenced the appellant to a four-year term for housebreaking and a consecutive five-year term for the assault.
- The appellant appealed his conviction to the Supreme Court of South Carolina.
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Issue:
Does voluntary intoxication constitute a valid defense to a crime that requires proof of a specific intent?
Opinions:
Majority - Rhodes, Justice
No. Voluntary intoxication is not a valid defense to a crime requiring specific intent. Acknowledging that most jurisdictions permit such a defense, this Court explicitly rejects that majority rule and adopts a new rule for South Carolina. The Court's reasoning is grounded in public policy and the principle of personal accountability, stating that a person who voluntarily becomes intoxicated must be held responsible for their subsequent acts. Granting immunity for crimes committed in a state of voluntary intoxication would allow many offenders to go unpunished and would transgress the foundational legal principle of personal responsibility. The Court also found no error in the denial of a continuance, as the appellant failed to demonstrate any prejudice, and affirmed that using a prior conviction for larceny to impeach the appellant's credibility as a witness was proper.
Analysis:
This decision establishes a firm and clear minority rule in South Carolina regarding the defense of voluntary intoxication. By rejecting the distinction between general and specific intent crimes that is central to the majority rule in the United States, the court prioritized public policy and personal accountability over a technical analysis of mens rea. This ruling effectively eliminates the voluntary intoxication defense in the state, except in rare cases of permanent insanity. It creates a bright-line rule that simplifies the legal analysis but also imposes a stricter standard of criminal responsibility on defendants.
