Facts
- Theodore G. Hammond hosted a dinner party and consumed a mixed vodka drink and wine.
- Later, at a friend’s home, Hammond requested fruit juice because he believed he had consumed enough alcohol.
- The friend secretly mixed cranberry juice with vodka as a practical joke, disguising the alcohol; Hammond drank the mixture.
- Hammond drove afterward, was observed driving erratically, and was stopped by police.
- Police noted signs of intoxication, and breath tests showed BAC readings of .20 and .21.
- Hammond asserted an involuntary intoxication defense, claiming he did not know the fruit-juice drinks contained vodka.
Issues
- Whether involuntary intoxication as defined in N.J.S.A. 2C:2-8 may be asserted as a defense to DWI under N.J.S.A. 39:4-50.
Decision
- The Supreme Court of New Jersey reversed the Appellate Division and reinstated Hammond’s DWI conviction.
- The court held that involuntary intoxication under the Code of Criminal Justice does not apply to DWI prosecutions under the Motor Vehicle Act.
- The court treated DWI as an absolute-liability motor-vehicle violation focused on the objective fact of intoxication and operation, not the driver’s subjective awareness.
Legal Principles
- Motor-vehicle violations under the Motor Vehicle Act are not “offenses” governed by the New Jersey Code of Criminal Justice; Code defenses generally do not apply to such violations.
- DWI under N.J.S.A. 39:4-50 is an absolute-liability public-welfare offense centered on intoxication and vehicle operation, rather than mens rea.
- The legislative purpose of DWI enforcement is highway safety and deterrence by removing intoxicated drivers from the road regardless of how intoxication occurred.
Conclusion
In a DWI prosecution under New Jersey’s Motor Vehicle Act, a defendant may not rely on the Criminal Code’s involuntary intoxication defense because DWI is a separate, absolute-liability motor-vehicle violation aimed at protecting public safety through objective enforcement.