People v. Atkins

Atkins, along with his brother David, drove by Oliver Figg’s home in the Ponderosa Sky Ranch on Sepembter 27th. Atkins “flipped the bird” at Figgs as they drove by. Later that day, at 5pm, a neighbor saw David drive a white pickup truck into the Ponderosa Sky Ranch. He could not tell if David had a passenger with him. At 9pm, the same neighbor saw the pick truck drive out of the ranch at a high speed. A half hour later, a fire was reported.

At 9pm or 9:30pm, Atkin’s friends saw him at David’s apartment. Atkins was angrily throwing things around and was heavily intoxicated.

A soil sample collected by the fire marshal revealed the presence of gasoline, and Atkins’s wallet was found near the site where the fire started. Atkins told the firemarshall that he and his brother had been drinking all day and then drove to the ranch. He said that the area was overgrown with weeds, and decided to burn them with gasoline. However, the fire quickly spread, and Atkins panicked and fled. Atkins said that he did not mean any harm.

After a jury trial, Atkins found guilty arson of forest land. The trial court instructed the jury that arson is a general intent crime and that voluntary intoxication is not a defense. Atkins appealed, arguing that evidence of his intoxication should have been allowed to prove that he lacked the necessary intent to commit the crime. The Court of Appeals reversed, finding that arson required a specific intent to set a fire and instructing the jury that voluntary intoxication was not a defense to arson “denied the defendant the opportunity to prove he lacked the required mental state.” The Supreme Court of California granted the Government’s petition for review.