Diabetic Gets New Chance to Argue 'Involuntary Intoxication' Defense

A diabetic man convicted of trying to kill his wife won a chance for a new trial Monday when the Colorado Supreme Court ruled that low blood sugar can cause involuntary intoxication and leave someone incapable of following the law. Steve David Garcia Jr. was sentenced to 20 years in prison after a 1999 attack, in which he hit his wife on the head with a hammer and ran over her with a van, three days after she told him she wanted a divorce.

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A diabetic man convicted of trying to kill his wife won a chance for a new trial Monday when the Colorado Supreme Court ruled that low blood sugar can cause involuntary intoxication and leave someone incapable of following the law. The ruling said that under certain conditions, low blood sugar, or hypoglycemia, can meet the legal definition of involuntary intoxication as a defense against any crime. It was the first time the court had been presented with that question. Steve David Garcia Jr., an insulin-dependent diabetic, was convicted of second-degree attempted murder and first-degree assault and sentenced to 20 years in prison in a 1999 attack on his wife in Adams County, Colo. The state Supreme Court ruled that the trial judge was wrong when he limited Garcia’s ability to use involuntary intoxication from hypoglycemia as a defense. On a 4-3 vote, the justices said Garcia has to be given another chance to prove he was involuntarily intoxicated, but they left it up to the lower court judge to determine whether he should get a new trial. The dissenting justices agreed that insulin-induced hypoglycemia could result in involuntary intoxication but said Garcia’s low blood sugar was a result of his own actions. He had injected himself with a large dose of insulin on the day of the attack in anticipation of eating cake and ice cream at his daughter’s birthday party. Prosecutors said Garcia hit his wife on the head with a hammer and ran over her with a van in July 1999, three days after she told him she wanted a divorce. She suffered a fractured skull and other injuries. During his trial, Garcia didn’t dispute that he attacked his wife but said he wasn’t legally responsible because of hypoglycemia. Doctors testified that symptoms of the condition can include a loss of motor skills and an altered mental state that can “prevent rational thinking, planning, deliberation and even appreciation of what (one is) doing.” The judge had ruled that Garcia could argue he was involuntarily intoxicated only if he pleaded innocent by reason of insanity. Though he didn’t want to, Garcia used that plea. Two court-ordered mental health evaluations produced conflicting reports on whether Garcia was legally sane when he attacked his wife, and jurors rejected the insanity defense. The Supreme Court said the trial judge should have allowed Garcia to argue that he was involuntarily intoxicated without trying to prove he was insane. The justices said a defendant who argues involuntary intoxication must identify the cause and show he did not know it could trigger the condition. He must also show the intoxication disturbed his mental or physical capabilities and “resulted in the defendant’s lack of capacity to conform his or her conduct to the requirements of law,” they said. Dissenting justices Nathan Coats, Nancy Rice and Rebecca Love Kourlis said Garcia was given the opportunity to argue that insulin-induced hypoglycemia caused involuntary intoxication. They said Garcia’s statements indicated any intoxication was voluntary because he ignored medical advice and took too large a dose of insulin and then failed to eat anything afterward, despite at least three other bouts of hypoglycemia. Copyright 2005 Associated Press. All Rights Reserved. This material may not be published, broadcast, rewritten, or redistributed.

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