Hawai’i Supreme Court Announces Clarification of When Self-Induced Intoxication Exception of HRS § 702-230 Applies
The Supreme Court of Hawai’i (SCH) held that a trial court erred when it ruled that the HRS § 702-230(1) prohibition against self-induced intoxication as a defense barred a defendant from raising the defense of amphetamine psychosis resulting in a lack of criminal responsibility even though he was not intoxicated when he committed the crime.
Ramoncito D. Abion hit a gas station attendant in the back of the head with a hammer after she asked him to leave the station’s sidewalk where he was prone and talking to himself. There were multiple witnesses to the assault, and Abion confessed and turned over the hammer after police found him nearby.
Abion told police he hit the attendant but said “she did it first,” was “confused on what exactly he was referring to,” and was “cooperative” but “animated.” Abion did not appear to be intoxicated or experiencing withdrawal from drugs or alcohol, but he displayed “bizarre behavior,” including audio and visual hallucinations and paranoia. After he was arrested and charged, a panel of three medical examiners deemed Abion fit for trial. One of them, Dr. Martin Blinder, opined that Abion suffered from amphetamine psychosis and might be entitled to a lack of penal responsibility defense pursuant to HRS § 704-400.
Before trial, the prosecutor filed a motion to exclude the § 704-400 defense arguing State v. Young, 999 P.2d 230 (Haw. 2000) (ruling that a defendant suffering from a temporary impairment resulting from voluntary intoxication precludes a lack of penal responsibility defense), precludes Abion from invoking § 704-400 as a defense. The court agreed, ruling that a drug-induced mental illness constitutes self-induced intoxication which is barred from use as a defense by § 702-230(1). The court ruled the defense and Dr. Blinder’s testimony inadmissible. Following conviction and an unsuccessful appeal, attorney Benjamin E. Lowenthal helped Abion seek further review in the Hawai’i Supreme Court, arguing the trial court’s ruling prevented Abion from presenting a complete defense in violation of his due process rights.
The Court began by noting: “Central to the protections of due process is the right to be accorded ‘a meaningful opportunity to present a complete defense.’” State v. Matafeo, 787 P.2d 671 (Haw. 1990) (quoting California v. Trombetta, 467 U.S. 479 (1984).
It then stated that Young has been widely misconstrued, explaining: “in Young, whether a permanent mental illness caused by substance use was precluded by the self-induced intoxication exception was not at issue. Rather, Young applied the self-induced intoxication exception to an offense committed by a defendant who, at the time of the offense, was temporarily under the influence of voluntarily ingested substances. Young therefore involved a temporary impairment resulting from voluntary intoxication. Young did not address whether a defendant suffering from a permanent impairment caused by substance abuse is subject to the self-induced intoxication exception of HRS § 702-230.”
After reviewing the statute and its legislative history, the Court held that “the self-induced intoxication exception of HRS § 702-230(1) only applies to acts committed while a person is temporarily under the influence of voluntarily ingested substances.” Consequently, the Court ruled that the lower courts erred in not permitting testimony by Dr. Blinder based on the self-induced intoxication exception.
By not permitting Dr. Blinder’s testimony, the Court concluded that Abion was denied his right to present a complete defense. Whether Abion acted during a period of temporary self-induced intoxication was a fact in dispute, and Dr. Blinder’s opinion had a direct bearing on the matter.
He said methamphetamine can cause “structural changes in the brain,” which are “powerful enough to render somebody periodically psychotic.” Not every methamphetamine user experiences these changes, but those who do can, long after having given up methamphetamine, “continue to have paranoid thoughts” and “be susceptible to auditory hallucinations.” Dr. Blinder explained that methamphetamine use may cause people with a genetic predisposition for schizophrenia to develop symptoms that would not have manifested absent the methamphetamine. He believed Abion had a predisposition for psychosis activated by prolonged methamphetamine use and, although not intoxicated, was suffering from “permanent or long-term effects” of methamphetamine use.
Thus, the Court held that barring the defense and Dr. Binder’s testimony violated Abion’s constitutional right to present a complete defense.
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Related legal case
State v. Abion
|Cite||478 P.3d 270 (Haw. 2020).|
|Level||State Supreme Court|