Weaver v. State
1994 WL 673792, 643 N.E.2d 342, 1994 Ind. LEXIS 173 (1994)
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Rule of Law:
A defendant's voluntary intoxication defense requires evidence that intoxication was so severe as to preclude the ability to form specific intent, and a jury's finding against this defense will be affirmed if supported by sufficient evidence. Lay opinion testimony, even from a victim, is inadmissible to speculate on another person's intent or the cause of their actions.
Facts:
- On April 2, 1991, in Indianapolis, Jordan Weaver consumed lysergic acid diethylamide (LSD).
- Affected by his consumption of LSD, Jordan Weaver became violent and attacked some acquaintances.
- Jordan Weaver severely injured his girlfriend, Wendy.
- During the incident, Jordan Weaver was able to walk without difficulty, respond to threats and attacks, get into the back seat of a car and attempt to throttle Wendy, lift Wendy and hurl her to the ground, kick her, and bang her head.
- Jordan Weaver then got into Wendy's car and operated it to leave the scene, freed himself from the car by kicking out the windshield after it overturned, made his way to and into the Blickman house, struggled with the Blickmans, and continued to struggle with police when they arrived.
Procedural Posture:
- Jordan Weaver was convicted by a trial court jury of attempted murder, confinement, battery, two counts of battery, resisting law enforcement, and criminal mischief.
- Jordan Weaver appealed his convictions to the Indiana Court of Appeals.
- The Indiana Court of Appeals reversed the attempted murder conviction but affirmed each of the other convictions.
- The State sought and was granted transfer by the Indiana Supreme Court.
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Issue:
Does the State present sufficient evidence to disprove a voluntary intoxication defense in an attempted murder case, and is a victim's lay opinion on the defendant's intent and the cause of the incident admissible?
Opinions:
Majority - Dickson, Justice
Yes, the State presented sufficient evidence to disprove Jordan Weaver's voluntary intoxication defense because a reasonable jury could find he was not so intoxicated as to be unable to form the intent to kill. No, a victim's lay opinion on the defendant's intent and the cause of the incident is not admissible, as lay witnesses may not testify as to another person's intent or legal conclusions. The court applied its standard of review for sufficiency of evidence, which mandates affirming a conviction if, considering probative evidence and reasonable inferences supporting the verdict (without reweighing evidence or assessing credibility), a reasonable trier of fact could find each element proven beyond a reasonable doubt. It adopted Chief Judge Sharpnack's analysis, detailing Weaver's numerous complex and goal-directed actions throughout the incident. This evidence, combined with the jury's role in assessing Weaver's credibility and apparent disorientation at trial, allowed a reasonable jury to conclude that his intoxication was not so severe as to preclude his ability to form the intent to kill, which is the core requirement for a voluntary intoxication defense (citing Ferguson v. State). Regarding the lay opinion, the court reiterated the established rule (pre-1994 Indiana Rules of Evidence) that a witness may not offer an opinion on another person's state of mind or thought processes, limiting testimony to observable facts (citing Kimp v. State and Johnson v. State). While acknowledging that the newly adopted Indiana Evidence Rule 701 permits lay opinions rationally based on perception and helpful to understanding testimony or determining a fact, and Rule 704(a) allows opinions on ultimate issues, Rule 704(b) explicitly excludes opinions concerning intent or legal conclusions in criminal cases. Despite the victim's unique perspective, her opinion on Weaver's intent or the cause of the attack would constitute impermissible speculation and not assist the jury, whose role it is to draw conclusions from factual descriptions.
Concurring - DeBruler, Justice
Yes, the trial court correctly excluded the victim's lay opinion on the defendant's intent to kill, as such testimony is explicitly precluded by evidentiary rules concerning intent in criminal cases. Justice DeBruler concurred with the majority, emphasizing the distinction between admissible opinion testimony on a person's capacity to form intent and inadmissible opinion testimony on a person's actual intent. Under Indiana Evidence Rule 701, a witness may offer an opinion on a person's capacity to form intent if it is rationally based upon their perceptions and observations, and it is helpful to the determination of a fact in issue. However, Rule 704(b) specifically excludes opinion testimony concerning intent in a criminal case. The opinion explained that while the victim could have offered an admissible opinion about Weaver's level of intoxication and whether he appeared capable of forming intent, she was correctly prevented from testifying about whether she believed he actually intended to kill her. This distinction is particularly important when a voluntary intoxication defense is raised to challenge the prosecution's proof of intent.
Analysis:
This case is significant for clarifying the application of the voluntary intoxication defense, affirming that even extreme intoxication does not automatically negate specific intent if the defendant's actions demonstrate a capacity for complex, goal-directed behavior. It also reinforces the strict prohibition on lay witness testimony regarding another's specific intent or legal conclusions in criminal cases, even from a victim with intimate knowledge of the defendant, underscoring the jury's exclusive role in determining state of mind. The distinction, particularly emphasized in the concurrence, between a defendant's capacity to form intent and their actual intent is a crucial point for attorneys when presenting or challenging such defenses, especially under modern rules of evidence.
