## Facts

- Robert William Altimus drove in Minneapolis and made an illegal left turn from the right-hand lane, colliding with a northbound garbage truck.
- After the collision, he backed up and drove slowly away in a badly damaged vehicle; officers followed and stopped him about a block away.
- Officers observed signs of confusion; Altimus complained of head and shoulder pain and asked to be taken to the hospital.
- Altimus gave a false name and produced paperwork suggesting a transfer of title from his true name to the false name.
- At the hospital, after police discovered his identity, Altimus fled; he was later located and apprehended following an altercation in which he struck an off-duty uniformed officer.
- A municipal court jury found Altimus guilty of careless driving and hit-and-run involving an attended vehicle, and not guilty of simple assault.
- At trial, Altimus claimed that prescribed Valium caused an unexpected adverse reaction, leaving him without recollection of the events and unable to control his conduct.
- Altimus requested a jury instruction on involuntary intoxication; the trial court refused.

## Issues

1. Whether the trial court committed prejudicial error by refusing to instruct the jury on temporary insanity due to involuntary intoxication based on a prescribed drug.
2. Whether the trial court’s instructions on intent for careless driving and hit-and-run were erroneous.

## Decision

- The Minnesota Supreme Court reversed the convictions and remanded for a new trial.
- The court held that the evidence was sufficient to require submitting to the jury the defense of temporary insanity due to involuntary intoxication.
- The court stated that Minnesota’s voluntary intoxication statute applies only to specific-intent crimes and does not apply to the charged traffic offenses.
- Because the refusal to instruct removed a potentially complete defense from the jury, the error was prejudicial.

## Legal Principles

- Voluntary intoxication is a defense only when a specific intent, motive, or purpose is an element of the offense; it is not applicable to traffic offenses that do not require specific intent.
- For general-intent or negligence-based traffic offenses, temporary insanity due to involuntary intoxication is a complete defense if the defendant proves by a preponderance of the evidence that, due to a defect of reason caused by the involuntary intoxication, the defendant did not know the nature of the act or that it was wrong (M’Naghten-type standard).
- When intoxication arises from medication taken pursuant to medical advice, the defense is available only if the defendant ingested the drug without knowing, and without reason to know, that it was likely to have an intoxicating effect.
- A defendant is entitled to a requested instruction on a recognized defense when the record contains sufficient evidence to raise a jury question on that defense.

## Conclusion

The court ordered a new trial because the record supported an involuntary-intoxication theory tied to Minnesota’s temporary-insanity standard, and the jury should have been instructed to decide whether prescribed Valium rendered the defendant incapable of criminal responsibility for the charged traffic offenses.


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