State v. Coates

Officer Long was driving when he saw a Thunderbird collide with another vehicle. The car that had been hit pulled off the road, but the Thunderbird kept going. Officer Long followed, and the Thunderbird’s engine died, prompting the driver to pull to the side of the road. Coates (defendant) exited the vehicle. Long told Coates he should return to the scene of the accident, which Coates agreed to do. When Coates and Long got closer to the location of the accident, the sight of a police car’s flashing lights made Coates change his mind about returning to the scene. Officer Long sensed that there was something wrong with Coates’s mental state, so he allowed Coates to return to his own vehicle. While on the way to Coates’s car, Coates stabbed Long in the back twice and kept walking. A Breathalyzer test later indicated that Coates had a blood-alcohol level of .16 percent. At trial, Coates said he did not remember the accident or assault and that he had drunk a large amount of alcohol on the night in question. The trial judge instructed the jury on the intoxication defense, which provides that intoxication is only a proper consideration in determining if a particular, required mental state could be formed at the time of the crime. The judge instructed that the defense only applies in circumstances where the requisite mental state is intent, knowledge, or recklessness. The judge forbade the jury from considering the intoxication defense in relation to the lesser-included charge of third-degree assault, which required a negligent mental state. The judge’s instructions were based on two recent amendments to the criminal code: (1) the replacement of general and specific intent requirements with four levels of culpability: intent, knowledge, recklessness, and negligence; and (2) the change in the intoxication statute to refer to a “particular mental state” instead of “purpose, motive, or intent.” The jury acquitted Coates of second-degree assault, but convicted him of third-degree assault. Coates appealed.