City of Minneapolis v. Altimus case brief, 238 N.W.2d 851 (1976)

City of Minneapolis v. Altimus

238 N.W.2d 851 (1976) 

FACTS

-Defendant was involved in a hit and run accident. Jury found him guilty of careless driving and of a hit and run.

-D argues that the trial judge erred by not instructing the jury on the defense of involuntary intoxication.  --

-D claims that his doctor prescribed to him Valium to cure his back pain and after he took it, the medicine started to have strange effects on him (D) and at the time of the accident, he was under its effects.

ISSUE
Did the trial court err by not instructing the jury on the defense of involuntary intoxication?

HOLDING
Yes: the jury should have been instructed on the defense of involuntary intoxication.

RULE
There are 4 kinds of involuntary intoxication:

1. coerced intoxication
2. pathological intoxication
3. intoxication by innocent mistake
4. intoxication resulting from ingestion of a medically prescribed drug

For intoxication resulting from prescribed drug, the defendant must meet 3 elements:

1. The defendant must not know, or have a reason to know, that the drug will have such effects on him.
2. The prescribed drug is the cause of the intoxication and not the cause of something else.
3. The defendant due to this intoxication is temporarily insane.

ANALYSIS
A jury has to decide whether these 3 elements are met and the defendant in the current case should have had the instruction of involuntary intoxication.

Link to Case: City of Minneapolis v. Altimus