Walden v. State
178 Tenn. 71, 156 S.W.2d 385, 14 Beeler 71 (1941)
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Rule of Law:
Voluntary intoxication is not a defense to a general intent crime, such as rape, unless the intoxication results in settled insanity or negates a required specific intent, which rape does not possess.
Facts:
- Roy Walden knew the Sorrell family, who owned a lunchroom near his home, and their eight-and-a-half-year-old daughter, Nancy Ruth Sorrell.
- On the evening of September 8, 1940, Nancy Ruth was left home alone, with the doors unlocked, after an employee took her home from the family's lunchroom.
- Later that night, Walden was at the lunchroom and was present when Mr. and Mrs. Sorrell, along with their employee and Mrs. Sorrell's brother, decided to leave for Knoxville at 3:10 A.M.
- Knowing Nancy Ruth was alone, Walden went to the Sorrell home and told her that her parents wanted her, thereby luring her out of the house.
- Walden took Nancy Ruth into the woods and sexually assaulted her multiple times.
- The next morning, Walden returned to his own home and changed his muddy clothes.
- Walden claimed that due to consuming alcohol and sedative tablets (veronal and luminal), he was intoxicated to the point of unconsciousness and had no memory of committing the crime.
- When confronted by officers, Walden lied about his whereabouts on the night of the assault.
Procedural Posture:
- Roy Walden was indicted for the rape of Nancy Ruth Sorrell in the Criminal Court of Knox County.
- At trial, Walden entered pleas of 'not guilty' and 'insanity'.
- A jury in the trial court found Walden guilty and fixed his punishment at death by electrocution.
- The trial court denied Walden's motion for a new trial and entered judgment in accordance with the jury's verdict.
- Walden, as plaintiff in error, perfected an appeal from the judgment to the Supreme Court of Tennessee.
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Issue:
Does voluntary intoxication, to the point of being unconscious of one's actions but short of producing settled insanity, constitute a valid defense to the general intent crime of rape?
Opinions:
Majority - Justice McKinney
No. Voluntary intoxication does not mitigate a crime or serve as a defense to a general intent crime like rape. The only intent required for rape is the intent to perform the acts constituting the offense, and this is not negated by voluntary drunkenness. The court reasoned that under the common law, a person who voluntarily becomes intoxicated and commits a crime is fully responsible, as the law constructively supplies the criminal intent. The only exceptions are when intoxication results in settled insanity or when it negates a specific intent, such as premeditation in first-degree murder, which is an element not required for rape. The court also found Walden's claim of being unconscious unconvincing, citing his ability to concoct a story to lure the child and his subsequent actions to conceal his guilt, such as changing his clothes and lying to the police.
Analysis:
This case reaffirms the fundamental common law principle that voluntary intoxication is not an excuse for criminal conduct. It clearly distinguishes between general intent crimes, for which intoxication is no defense, and specific intent crimes, where it may be relevant to negate the required mental state. The decision reinforces the public policy that individuals are responsible for the consequences of their voluntary actions, including crimes committed while under the influence. This ruling provides a clear precedent in Tennessee law, ensuring that the defense of intoxication is narrowly applied and does not absolve defendants of responsibility for crimes like rape.
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