People v. Garcia
Supreme Court of Colorado
113 P.3d 775 (2005)
Diabetic Steve Garcia (defendant) injected his prescribed insulin dose but did not eat afterward, and while running errands with his wife Johnie, he inexplicably struck her with a hammer and then ran her over with their van as she tried to flee, severely injuring her; the State (plaintiff) charged him with attempted first-degree murder, and Garcia sought to present expert testimony that his insulin-induced hypoglycemia impaired his rational thinking and prevented him from forming the requisite intent. The trial court categorically ruled hypoglycemia could never support an involuntary intoxication defense, instructed the jury only on insanity, and Garcia was convicted; an intermediate appellate court found this error, and the state sought and obtained Colorado Supreme Court review.
Whether insulin-induced hypoglycemia, resulting from a properly prescribed dose combined with the defendant's own failure to eat afterward, can constitute the basis for an involuntary intoxication defense to a specific-intent crime.