People v. Atkins

Robert Atkins (defendant) told his friends that he was going to burn down the house of Orville Figgs. The next day, a fire was reported in the canyon where Figgs lived. A soil sample collected by the fire marshal revealed the presence of gasoline, and Atkins’s wallet was found near the site where the fire had originated. When interviewed by the fire marshal, Atkins said that he and his brother had been drinking all day and then drove to the canyon and kept drinking. Atkins said that the area was overgrown with weeds, which he decided to burn with gasoline. The fire spread quickly, and after Atkins and his brother tried unsuccessfully to extinguish the fire, they panicked and fled. Atkins said that he did not mean any harm by setting the fire, and maintained that the fire was an accident. Atkins was subsequently charged with arson of forest land. The trial court instructed the jury that arson was a general-intent crime and that voluntary intoxication was not a defense to arson. The jury convicted Atkins. On appeal, Atkins argued that evidence of voluntary intoxication was admissible to show that he lacked the necessary intent to commit the crime. The court of appeal found that arson required a specific intent to set fire to or burn forest land, and that evidence of Atkins’s voluntary intoxication should have been admitted. The court of appeal reversed based on the trial court’s instruction that voluntary intoxication was not a defense to arson. The Supreme Court of California granted the state’s petition for review.