## Facts

- Allen Lee Hall killed Gilford Eugene Meacham in Meacham’s car; Hall later surrendered and admitted shooting him.
- Physical evidence linked Hall to the car, including his fingerprint and an overnight bag containing his social security card.
- The State contended Meacham picked up Hall as a hitchhiker, Hall shot Meacham after passing Des Moines, robbed him of $208, disposed of the body, and fled.
- Hall claimed he took a pill from an acquaintance that he did not know contained LSD and that it caused hallucinations and delusions at the time of the killing.
- Defense experts testified the pill likely contained LSD and could have produced a psychotic reaction.
- At trial, Hall asserted insanity based on the alleged drug-induced mental condition.

## Issues

1. Whether a mental condition produced by voluntary ingestion of a hallucinogenic drug may support a complete insanity defense, rather than being treated under voluntary intoxication rules.
2. Whether the trial court erred by refusing to instruct the jury on “drug-induced temporary insanity” as a complete defense and by instead giving standard insanity and intoxication instructions.

## Decision

- The Supreme Court of Iowa affirmed the first-degree murder conviction.
- The court held that temporary mental disturbance directly resulting from voluntary drug ingestion is governed by intoxication doctrine, not a standalone insanity defense.
- A full insanity defense remains available only if drug use causes a continuing mental disease or defect that satisfies the jurisdiction’s insanity standard.
- The trial court properly refused a special instruction recognizing temporary drug-induced insanity as a complete defense and properly submitted the case under conventional insanity and intoxication instructions.

## Legal Principles

- Voluntary ingestion of an intoxicant or hallucinogenic drug, even if its precise effects are not anticipated, does not provide a complete excuse from criminal responsibility.
- Temporary psychosis or delusions that are the immediate effects of voluntarily taken drugs are treated as voluntary intoxication.
- Voluntary intoxication is generally not a defense to crime but may be considered on the question whether the defendant formed the specific intent required for the charged offense.
- A defendant may assert insanity only upon proof of a qualifying mental disease or defect; a “settled” or continuing disorder precipitated by drugs may qualify, but a transient drug effect does not.
- Trial courts are not required to give special jury instructions creating an independent defense of temporary drug-induced insanity when standard insanity and intoxication instructions fairly present the issues.

## Conclusion

The court held that Hall’s claimed LSD-induced hallucinations, to the extent they resulted from voluntary ingestion and were temporary, could be considered only under intoxication principles (including specific intent), and did not require an instruction allowing complete acquittal on a theory of temporary drug-induced insanity.


State v. Hall, 214 N.W.2d 205 (Iowa 1974)