People v. Saille
Supreme Court of California
820 P.2d 588 (1991)
After being repeatedly turned away from a cafe while visibly intoxicated, Saille (defendant) threatened to get a gun and kill the security guard, retrieved a rifle, and returned; in the ensuing struggle over the gun, it discharged and killed a patron. Saille's blood alcohol was .19. The trial court instructed the jury that it could consider his voluntary intoxication only in deciding whether he had the specific intent to kill, without giving a sua sponte instruction tying intoxication to premeditation or offering a voluntary-manslaughter theory based on intoxication alone. Saille was convicted of first-degree murder and attempted murder, and appealed.
Whether evidence of voluntary intoxication may be used to reduce murder to involuntary manslaughter if the defendant sufficiently shows the intoxication prevented him from forming the specific intent to kill, and whether the trial court must instruct on this sua sponte.