Friday, November 15, 2013

State v. Sexton case brief

State v. Sexton case brief summary
904 A.2d 1092 (2006)

In defendant's prosecution for second-degree murder, the District Court of Vermont, Unit No. 2, Chittenden Circuit (Vermont), granted the State of Vermont's motion for permission to pursue an interlocutory appeal from orders holding that defendant could rely on defenses of diminished capacity due to voluntary intoxication and of legal insanity caused when a latent mental disease or defect was activated by his consumption of illegal drugs.

Defendant sought to introduce evidence that he killed his victim while suffering from a psychotic episode caused when a two-month period of ingesting LSD, ending a few weeks before the crime, triggered a latent psychological vulnerability.

  • The appellate court answered the first two of three questions certified by the trial court by holding that because the common law allowed the defense of diminished capacity to specific intent crimes, defendant was entitled to present evidence that his diminished capacity, due either to voluntary intoxication or mental disability, prevented him from forming the specific intent to commit second-degree murder. 
  • The appellate court answered the third certified question by holding that the trial court's proposed instruction setting forth defendant's insanity defense was incorrect under Vt. Stat. Ann. tit. 13, § 4801. 
  • A mental state self-induced by the voluntary ingestion of alcohol or illegal drugs could not excuse criminal liability. 
  • An exception recognized in some jurisdictions for insanity caused by long-term substance abuse did not apply because of the brevity of defendant's LSD ingestion and the disappearance of his psychosis after the crime.

The appellate court affirmed the trial court order denying the State's motion to preclude evidence at trial regarding defendant's diminished capacity due to voluntary use of illegal drugs. The trial court order allowing defendant to present an insanity defense based on the voluntary consumption of illegal drugs that activate a latent mental disease or defect is reversed. The case was remanded for further proceedings.

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