State v. Coates

Coates (defendant) caused a car accident and fled the scene, and when Officer Long tried to walk him back to it, Coates stabbed the officer twice in the back. A later Breathalyzer test showed Coates's blood-alcohol level at .16 percent, and Coates testified he remembered nothing of the accident or the stabbing. The trial judge instructed the jury that voluntary intoxication could be considered only for crimes requiring intent, knowledge, or recklessness, and not for the lesser-included charge of third-degree assault, which requires only negligence. The jury acquitted Coates of second-degree assault but convicted him of third-degree assault, and he appealed the exclusion of the intoxication defense.