People v. Kelly – California
Nature of the Case
This case involves the use of the insanity defense by a habitual drug user. The court distinguishes voluntary intoxication from psychotic episodes brought on by habitual drug use.
Facts
Valerie Dawn Kelly (D) was 18 when this crime was committed. Kelly began taking drugs when she was 15. When she was 18 she began taking LSD and mescaline regularly. She had been found wandering the airport in a drug induced state and her mother picked her up and took her back to her apartment. The next morning Kelly called her mother and asked to be driven to her home. Her mother noticed that seemed to be disoriented. Shortly after breakfast Kelly stabbed her mother with several kitchen knives, wounding her severely.
At trial, medical experts testified that Kelly had multiple personality disorder and schizophrenia. They also testified that after she was unable to perceive reality and reason properly after taking drugs. This psychosis would remain even after the defendant was no longer under the influence of the drugs. At trial Kelly was denied the defenses of insanity and unconsciousness and was found guilty. The defendant appealed.
Issue
- Can a defendant advance an insanity defense in a general intent crime if that insanity was the consequence of voluntary drug use that has produced lasting psychotic effects?
Holding and Rule of Law
- Yes. A defendant can advance an insanity defense in a general intent crime if that insanity was the consequence of voluntary drug use that has produced lasting psychotic effects.
When long lasting intoxication continues after a drug is voluntarily taken, the drug user remains legally insane. Settled insanity produced by long continued intoxication affects responsibility the same was as insanity produced by any other cause. However, this must be settled insanity, something that is long term and not temporary. It need not be permanent, on a 24 hour basis, but long lasting voluntary drug use can produce this settled insanity. Under the M’Naghten test, a person is insane if he is incapable of knowing or understanding the nature of his actions. Long term drug use can have this effect and can produce permanent changes in the function of the brain. This is what happened in the present case. Kelly never understood the nature of her actions and is entitled to use the insanity defense.
Disposition
Reversed and remanded.