State v. Cameron

Supreme Court of New Jersey, 1986

Facts: D Michele Cameron was indicted for second degree aggravated assault in violation of NJSA 2C:12-1(b)(1); possession of a weapon, a broken bottle, with a purpose to use it unlawfully, contrary to NJSA 2C…..and fourth degree resisting arrest. Jury convicted D on all charges. On 6/6/81 D had approached victim McKinney and a group of men playing cards on a vacant lot.  D disrupted the game w/her conduct and they moved to another location on the lot.  D followed them and turned over the table.  D attacked McKinney with a broken bottle an McKinney sustained and injury to his hand requiring 36 stitches and causing permanent injury.  D then reacted with violence to the arrival of the police, throwing a bottle at their vehicle, shouting obscenities and trying to fight them off.  She had to be restrained and handcuffed in the police wagon.

Procedural History: Trial Court refused the defendant’s request to be charged intoxication.  The appellate Division reversed D’s convictions, holding that it was error not to have given an intoxication charge.

Issue: Was evidence sufficient to require the trial court to charge the jury on D’s intoxication?

Holding: No.  Evidence was not sufficient to require the trial court to charge the jury on D’s intoxication.

Reasoning: Voluntary intoxication is a defense when the requisite culpability for a crime is “purposefully” or “knowingly” (can be equated to specific intent).  Proof of voluntary intoxication would negate the culpability elements in the offenses of which the D is convicted.  The charges in this case all required purposeful conduct.  However, D need to show “such a great prostration of the faculties that the requisite mental state was totally lacking.  That is, to successfully invoke the defense, an accused must show that he was so intoxicated that he did not have the intent to commit such an offense…” (State v. Stasio).  Measured by this standard, it is apparent that the record of this case is insufficient to have required the trial court to grant D’s request to charge intoxication. D had only a pint of wine and shared it with others.  She remembered details of the entire incident.  The court cannot find sufficient evidence to permit a jury to say that D was not capable of behaving with this violent purpose without being intoxicated.

Disposition: Decision of Appellate Court reversed.  The trial court correctly refused D’s request…

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