## Facts

- Guadalupe A. Sanchez attended a birthday party at a trailer on a horse farm where alcohol was consumed.
- After being asked to leave, Sanchez later returned to the trailer with a handgun.
- The State alleged Sanchez used the gun to intimidate those present, confined 17-year-old H.S., and raped her.
- Sanchez was charged with rape (Class A felony) and criminal confinement (Class B felony).
- At trial, Sanchez argued voluntary intoxication prevented him from forming the required mental state for the offenses.
- The trial court instructed the jury that voluntary intoxication was not a defense under Indiana Code § 35-41-2-5, preventing the jury from using intoxication to negate mens rea.
- The jury convicted Sanchez of both offenses, and he received a lengthy prison sentence.

## Issues

1. Whether Indiana Code § 35-41-2-5, which bars the use of voluntary intoxication to negate a crime’s mens rea, violates the Indiana Constitution’s Due Course of Law provision (Ind. Const. art. 1, § 12).
2. Whether the Indiana Constitution otherwise guarantees a defendant the right to present voluntary intoxication evidence to disprove intent.
3. Whether giving an instruction implementing the statutory bar constituted reversible instructional error in this case.

## Decision

- The Indiana Supreme Court affirmed the convictions.
- The court held Indiana Code § 35-41-2-5 is constitutional under the Indiana Constitution.
- Because the statute is valid, instructing the jury that voluntary intoxication is not a defense was not error.
- The court also indicated that, even if some constitutional entitlement to present such evidence existed, Sanchez did not show reversible prejudice on the facts.

## Legal Principles

- The legislature may define crimes and their mental elements and may declare voluntary intoxication legally irrelevant to whether a defendant had the required mens rea.
- Indiana’s Due Course of Law clause does not require the State to allow voluntary intoxication evidence to negate mens rea absent a demonstrated historical or structural basis for broader state protection.
- A defendant’s right to present a defense is subject to valid legislative limits that determine what evidence is legally material to an element or defense.
- When a statute validly eliminates voluntary intoxication as a mens-rea-negating doctrine, a jury instruction reflecting that rule is proper.

## Conclusion

The Indiana Supreme Court upheld Indiana Code § 35-41-2-5 and affirmed Sanchez’s rape and criminal confinement convictions, holding that Indiana’s Constitution does not require admission or consideration of voluntary intoxication evidence to negate mens rea.


Sanchez v. State, 749 N.E.2d 509 (Ind. 2001)