## Facts

- Off-duty police officer Matt Long saw a blue Thunderbird collide with another car and followed it when it left the scene.
- After the Thunderbird stopped, Long identified himself as a police officer and urged the driver, Steven Kenneth Coates, to return to the accident scene.
- As they neared the scene and observed a patrol car’s emergency lights, Coates refused to proceed; Long agreed Coates could return to his car.
- Near Long’s truck, Coates stabbed Long twice in the back and returned to his own vehicle.
- Responding officers arrested Coates and his passenger; a knife was found on the passenger, but the assault knife was not recovered at the scene.
- Coates’s car was sealed, towed, and impounded; officers later obtained a warrant to search the car.
- A Breathalyzer indicated Coates’s blood alcohol level was about 0.16%; at trial he claimed heavy drinking and no memory of the collision or stabbing.
- Coates was charged with second-degree assault; the jury acquitted on that charge but convicted him of third-degree assault as submitted to the jury with a criminal-negligence mental state.

## Issues

1. Whether evidence seized from Coates’s automobile under a warrant should have been suppressed because the affidavit included information derived from an allegedly unlawful statement.
2. Whether, once voluntary intoxication is raised, the State must disprove intoxication beyond a reasonable doubt.
3. Whether voluntary intoxication evidence may be considered to negate the mental state of criminal negligence.

## Decision

- The Washington Supreme Court affirmed the third-degree assault conviction.
- The court upheld denial of suppression because, even excluding any allegedly tainted information, the remaining affidavit facts established probable cause for the vehicle-search warrant.
- The court held the State has no separate burden to disprove voluntary intoxication; intoxication is evidence the jury may consider when deciding whether the State proved the required mental state beyond a reasonable doubt.
- The court held voluntary intoxication cannot be used to negate criminal negligence; the intoxication instruction may be limited to offenses requiring intent, knowledge, or recklessness.

## Legal Principles

- When a warrant affidavit includes allegedly unlawful information, the proper inquiry is whether the untainted portions, standing alone, provide probable cause; if so, suppression is not required.
- Voluntary intoxication is not an element the State must disprove; it is a type of evidence relevant to whether the State proved mens rea beyond a reasonable doubt.
- Voluntary intoxication may be considered only as to mental states that depend on the defendant’s actual awareness or purpose (intent, knowledge, recklessness), not criminal negligence.
- Criminal negligence is measured by an objective reasonable-person standard (failure to be aware of a substantial risk a reasonable person would recognize); self-induced intoxication does not alter that standard.

## Conclusion

The court affirmed Coates’s conviction, holding the search warrant was supported by probable cause independent of any allegedly unlawful statement and clarifying that voluntary intoxication neither shifts a disproving burden to the State nor permits a defendant to avoid liability for crimes defined by criminal negligence.


State v. Coates, 735 P.2d 64 (Wash. 1987)