Facts
- Eugene Raymond Cooper drove recklessly, prompting a police pursuit at high speed through rush-hour traffic.
- During the chase, Cooper shot at and wounded the pursuing officer.
- Cooper then kidnapped a man at gunpoint from a parking lot.
- The victim wrestled away the gun; the car crashed into a freeway divider; Cooper fled but was soon apprehended.
- Before trial, the court ordered a mental examination; court-appointed psychiatrists found Cooper competent to stand trial, and the court so ruled after a hearing.
- Cooper gave timely notice of an insanity defense and presented a psychiatrist and a psychologist regarding his mental condition at the time of the offenses.
- The defense experts tied Cooper’s claimed inability to know the nature/quality or wrongfulness of his acts to several days of amphetamine use, indicating he would have been sane absent the drugs.
- The trial court refused to instruct the jury on insanity and instead instructed only on voluntary intoxication under A.R.S. § 13-132.
Issues
- Whether the trial court erred by refusing to submit insanity to the jury and refusing insanity instructions in light of the defense expert testimony.
- Whether a mental state allegedly caused by voluntary amphetamine use can constitute legal insanity under Arizona’s M’Naghten rule, or is addressed only as voluntary intoxication relevant to specific intent.
Decision
- The Arizona Supreme Court affirmed the convictions and concurrent sentences of 30 years to life for kidnapping and assault with a deadly weapon.
- The court held the trial judge properly refused to submit insanity to the jury because the evidence did not raise an insanity issue under Arizona law.
- The court approved treating the evidence as voluntary intoxication, not insanity, and upheld the intoxication instruction given under A.R.S. § 13-132.
Legal Principles
- Sanity is presumed in criminal cases; a defendant must produce sufficient evidence to generate a doubt as to sanity before sanity becomes an issue requiring the State to prove sanity beyond a reasonable doubt.
- Arizona applies the M’Naghten test: a defendant is insane only if, due to mental disease or defect, he did not know the nature and quality of the act or did not know the act was wrong.
- Voluntary intoxication is not a defense but may be considered only to determine whether the defendant formed the required specific intent (A.R.S. § 13-132).
- A transient, self-induced drug condition, standing alone, does not qualify as a “mental disease or defect” for purposes of the insanity defense and does not require an insanity instruction.
Conclusion
Because the defense evidence attributed Cooper’s claimed inability to understand his conduct to voluntary amphetamine use rather than a qualifying mental disease or defect, the trial court properly withheld insanity from the jury and limited consideration of intoxication to specific intent; the convictions and sentences were affirmed.