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State v. Hammond

Supreme Court of New Jersey
571 A.2d 942 (1990)


Facts

Theodore Hammond (defendant) and several friends went to the home of Henry Spence to drink alcohol and socialize. While there, Hammond asked for only fruit juice because he had consumed alcohol earlier in the evening. Unbeknownst to Hammond, Spence mixed the fruit juice with vodka so that Hammond could not detect the alcohol. While at Spence’s home, Hammond consumed nearly 12 ounces of vodka. Thereafter, the party of friends went to a bar. While at the bar, Hammond did not drink alcohol. Instead, Hammond told his friends he felt sick and left the bar. While driving home, a police officer pulled over Hammond for erratic driving. Hammond failed two breathalyzer tests. The State of New Jersey (plaintiff) charged Hammond with driving under the influence of alcohol (DUI). At a trial, Spence testified that he had given Hammond the mixed drinks in a manner that prevented Hammond from detecting the vodka. Hammond argued that his involuntary intoxication was a defense to the DUI charge. The trial court agreed that involuntary intoxication is a defense to a DUI charge but disagreed that Hammond was unaware of the alcohol he had consumed. Hammond was convicted, and he appealed. The law division affirmed. The appellate court reversed, holding that the involuntary intoxication defense applied to a DUI charge under the state’s motor vehicle act. The Supreme Court of New Jersey granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Handler, J.)

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