This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The Defendant was involved in a methamphetamine-fueled, high-speed car chase, leading to convictions for driving while impaired (DWI) and aggravated fleeing a law enforcement officer. The chase involved erratic driving, attempts to evade police using spike strips, and resulted in a crash. High levels of methamphetamine were found in the Defendant's blood. The Defendant did not challenge the DWI conviction but appealed the aggravated fleeing conviction on several grounds, including the denial of a jury instruction on voluntary intoxication and the exclusion of defense witnesses' testimony (paras 1-4, 14).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred by denying a requested jury instruction on voluntary intoxication, committing fundamental error by not giving a mistake-of-fact instruction, denying a request to instruct the jury on the lesser-included offense of resisting, evading, or obstructing an officer, and violating his constitutional right to present a defense by disallowing the testimony of certain defense witnesses due to late disclosure (paras 1, 4).
- Plaintiff-Appellee: Contended that voluntary intoxication is not a defense to aggravated fleeing, a mistake-of-fact defense is not appropriate based solely on voluntary intoxication, and the Defendant was not entitled to a lesser-included offense instruction or the testimony of untimely-disclosed witnesses (paras 6, 16, 26, 34).
Legal Issues
- Whether the district court erred by refusing the Defendant's requested jury instruction on voluntary intoxication.
- Whether the district court committed fundamental error by not giving a mistake-of-fact instruction.
- Whether the Defendant was entitled to a jury instruction on the lesser-included offense of resisting, evading, or obstructing an officer.
- Whether the district court violated the Defendant's constitutional right to present a defense by excluding the testimony of certain defense witnesses due to late disclosure.
Disposition
- The Court of Appeals affirmed the judgment and sentence, concluding that none of the Defendant's claims had merit (para 36).
Reasons
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Voluntary Intoxication: The Court held that voluntary intoxication is not a defense to aggravated fleeing, a general-intent crime, and therefore the district court properly denied the Defendant's requested instructions (paras 6-15).Mistake-of-Fact Instruction: The Court found that a mistake-of-fact defense is not appropriate where the mistake is caused solely by the defendant's voluntary intoxication. Thus, the district court did not commit fundamental error by not giving such an instruction (paras 16-24).Lesser-Included Offense Instruction: The Court concluded that the evidence did not support giving a lesser-included offense instruction for resisting, evading, or obstructing an officer because no rational view of the evidence could lead a jury to conclude that the Defendant did not "willfully and carelessly" drive in a manner that endangered the lives of others (paras 25-32).Exclusion of Defense Witnesses: The Court upheld the district court's decision to exclude the testimony of untimely-disclosed witnesses, finding that the Defendant failed to show any prejudice from the exclusion, as the witnesses' testimony would have been irrelevant to the defenses of voluntary intoxication and mistake of fact, which were not applicable in this case (paras 33-35).
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