## Facts

- A Tennessee highway patrolman, Morris, stopped a vehicle on State Highway 70 near Lebanon, Tennessee; the stopped car and the patrol car were positioned off the paved roadway on the shoulder, with lights and a spotlight on.
- Morris stood beside the stopped vehicle’s left front door while handling the driver’s documents; a passenger remained in the patrol car.
- James Edwards approached from the west at an estimated 50–60 mph on a heavily traveled, straight, level, paved highway with visibility extending more than a mile.
- Edwards drove with his right wheels on the shoulder, scraped along the stopped car, and struck Morris, throwing him about 45 feet.
- Edwards did not stop after the collision; the next morning he stated he knew he hit something but did not know what.
- An officer pursued and forced Edwards’s car to the shoulder; officers described Edwards as extremely intoxicated and possibly unable to comprehend what was said to him.
- Edwards’s wife told him she tried to get him to stop and he refused; Edwards offered no contemporaneous explanation for his intoxication.

## Issues

1. Whether the evidence permitted a finding of malice sufficient to support second-degree murder, rather than only involuntary manslaughter, for a vehicular killing by an intoxicated driver.
2. Whether extreme voluntary intoxication negated malice so as to bar a second-degree murder conviction.

## Decision

- The Tennessee Supreme Court affirmed the conviction for second-degree murder.
- The court held the evidence allowed the jury to infer malice from the surrounding circumstances of Edwards’s driving and conduct after impact.
- The court held voluntary intoxication did not negate malice as a matter of law in this context.

## Legal Principles

- A vehicular homicide may constitute involuntary manslaughter or second-degree murder depending on the facts and the degree of culpability shown.
- Malice for second-degree murder may be inferred from conduct demonstrating extreme recklessness and disregard for human life.
- Voluntary intoxication does not defeat a finding of malice where the circumstances otherwise support an inference of malice; a defendant cannot reduce murder by claiming he was too drunk to form malice.

## Conclusion

The court upheld a second-degree murder conviction where an extremely intoxicated driver, traveling at high speed and partly on the shoulder, struck and killed a clearly exposed patrolman and fled; the jury could infer malice from the driver’s extreme recklessness, and voluntary intoxication did not negate that malice.


Edwards v. State, 202 Tenn. 393 (Tenn. 1957)