Criminal Law Keyed to Johnson
People v. Whitfield
Whitfield (Defendant), who had a prior record of drunk-driving offenses, collided with another vehicle, killing the driver. Defendant was found unconscious in his vehicle, with empty cans of liquor. Evidence indicated that Defendant may have passed out just before the accident. At trial, Defendant attempted to prove that he did not act with implied malice aforethought, because he was so intoxicated that he was unconscious at the time of the accident. The trial court instructed the jury that: (1) voluntary intoxication could be considered in determining whether Defendant had specific intent; (2) every person who unlawfully kills another with malice aforethought is guilty of murder; and (3) malice may be express or implied, and (4) malice is implied when: (a) the killing resulted from an intentional act; (b) the natural consequences of the act are dangerous to life; and (c) the act was purposely performed with conscious disregard for life. The court distinguished between implied malice and gross negligence, the required mental state for the lesser offense of gross vehicular manslaughter. The trial court refused Defendant’s requested jury instruction that “[i]f you find that a defendant, while unconscious as a result of voluntary intoxication, killed another human being without intent to kill and without malice aforethought, the crime is involuntary manslaughter.” The jury found Defendant guilty of second-degree murder. Defendant appealed, arguing that the trial court erred in refusing his jury instruction. In reviewing the case, the court of appeals held that evidence of voluntary intoxication cannot be introduced to negate implied malice, because second-degree murder based on implied malice is not a specific-intent crime.
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