## Facts

- Two defendants’ appeals were decided together because both raised whether voluntary intoxication could negate mens rea for their convictions.
- Roy Lee Lundy was convicted in a bench trial of three counts of first-degree criminal sexual conduct for raping his adult sister, including three penetrations, while using a knife as a threatening weapon.
- Lundy presented expert and other evidence about his mental state, including that he had been sniffing glue and drinking alcohol immediately before the assault.
- The trial court rejected Lundy’s insanity defense and treated CSC I as a general-intent crime, making voluntary intoxication unavailable; the Court of Appeals affirmed.
- Dean V. Langworthy was convicted in a bench trial of second-degree murder after a night of alcohol and drug use in Ypsilanti; he shot and killed William Wedge following interactions that irritated him and amid evidence of discussion about robbing Wedge.
- The trial judge found Langworthy formed an intent to kill but also found he had no real concept of the consequences due to intoxication, and convicted him of second-degree rather than first-degree murder; the Court of Appeals affirmed.

## Issues

1. Whether first-degree criminal sexual conduct and second-degree murder are specific-intent crimes, such that voluntary intoxication may be used to negate the required mens rea.
2. Whether Michigan law should expand the category of specific-intent crimes to permit a voluntary intoxication defense for these offenses.

## Decision

- The Michigan Supreme Court affirmed both convictions.
- The Court held that first-degree criminal sexual conduct and second-degree murder are general-intent crimes.
- Because the offenses are general-intent, voluntary intoxication is not a defense to either charge.
- As to Langworthy, the trial court’s finding that he intended to kill meant the dispute was classification of the offense, not whether intoxication prevented intent formation on the facts.

## Legal Principles

- Voluntary intoxication may negate mens rea only for crimes requiring a specific intent beyond the intent to do the prohibited act.
- Offenses lacking an explicit heightened mental element (commonly expressed as “with intent to”) are generally treated as general-intent crimes for purposes of the intoxication defense.
- First-degree criminal sexual conduct and second-degree murder are general-intent crimes in Michigan; voluntary intoxication does not excuse or reduce liability for those offenses.
- Any broad reworking of the general-intent/specific-intent framework and the scope of intoxication defenses is primarily a legislative policy choice rather than a matter for case-by-case judicial expansion.

## Conclusion

The Court reaffirmed Michigan’s rule limiting voluntary intoxication to negating only specific-intent elements and refused to reclassify CSC I or second-degree murder as specific-intent crimes, leaving both convictions intact.


People v. Langworthy, 416 Mich. 630, 331 N.W.2d 171 (Mich. 1982)