## Facts

- Daniel Lee Graves was tried in the Court of Common Pleas of Northampton County and convicted by a jury of first-degree murder, robbery, and burglary; he received a life sentence for murder.
- The prosecution’s theory was that Graves and two cousins, acting pursuant to a prearranged plan, entered and burglarized the home of a 75-year-old man and robbed him, during which the victim suffered fatal injuries.
- Graves testified that earlier that day he consumed substantial amounts of wine and ingested LSD, experienced hallucinations, lost consciousness, and had limited amnesia for the events at the victim’s home.
- A defense psychiatrist examined Graves and testified that Graves was under the influence of both substances at the time of the attack and was not able to form a conscious intent to kill or assault.
- The trial court sustained an objection when defense counsel sought expert opinion on whether Graves could form the specific intent to steal at the time of the incident.
- The trial court also declined to instruct the jury that, if intoxication rendered Graves incapable of forming the intent required for burglary or robbery, he could not be convicted of those offenses.

## Issues

1. Whether evidence of voluntary intoxication may be introduced to negate the specific intent element of non-homicide specific-intent crimes, including burglary and robbery.
2. Whether the trial court erred by excluding expert testimony on the defendant’s ability to form the specific intent for burglary and robbery due to intoxication and by refusing a corresponding jury instruction.

## Decision

- The Supreme Court of Pennsylvania held that voluntary intoxication evidence is admissible to negate the specific intent element of any specific-intent offense, not solely the intent to kill for first-degree murder.
- The court overruled prior precedent that limited the intoxication doctrine to first-degree murder.
- The court ruled that the trial court erred by excluding psychiatric testimony relevant to whether Graves could form the specific intent required for burglary and robbery.
- The court ruled that the trial court erred by refusing to instruct the jury that it could acquit on burglary or robbery if it found intoxication created reasonable doubt as to the required specific intent.
- The matter was reversed in relevant part and remanded for proceedings consistent with the expanded rule.

## Legal Principles

- The prosecution must prove every element of an offense beyond a reasonable doubt, including any statutorily required specific intent.
- Evidence of voluntary intoxication is admissible when it tends to show the defendant could not form the specific intent required for a specific-intent crime.
- Voluntary intoxication does not excuse conduct as a matter of justification; it operates only to the extent it raises reasonable doubt about the existence of the required specific intent.
- Excluding otherwise relevant evidence bearing on specific intent, or refusing an instruction that permits the jury to consider such evidence, can constitute reversible error when specific intent is an element of the charged offense.

## Conclusion

The court expanded the use of voluntary intoxication evidence to all specific-intent crimes and held that the jury should have been allowed to consider expert testimony and instructions on whether intoxication prevented formation of the specific intent required for burglary and robbery.


Commonwealth v. Graves, 334 A.2d 661 (Pa. 1975)