Smith's Criminal Case Compendium
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State v. Meader, 377 N.C. 157 (Apr. 16, 2021)
In 2018, the defendant was charged with felony breaking or entering a motor vehicle and other crimes for an incident involving the theft of several items from a car. Before trial, the defendant gave notice of her intent to raise a defense of voluntary intoxication. The trial court denied her request for an instruction on voluntary intoxication, concluding that the evidence showed that she spoke clearly, was responsive to questions, walked under her own power, and followed instructions from officers. The Court of Appeals held over a dissent that the trial court did not err in declining to give the instruction. State v. Meader, 269 N.C. App. 446 (2020). On appeal, the Supreme Court applied the standard that, to obtain a voluntary intoxication instruction, a defendant must produce substantial evidence supporting a conclusion that she was so intoxicated that she could not form the specific intent to commit the crime. Reviewing the evidence, the high court concluded that the defendant’s behavior, while periodically unusual, did not show her to be “utterly incapable” of forming specific intent. To the contrary, the evidence showed her to be aware of surroundings and in control of her faculties, both before and after the police arrived. The court thus held that the trial court did not err and affirmed the decision of the Court of Appeals.
Justice Hudson, joined by Justice Morgan and Justice Earls, dissented. She wrote that the evidence, when viewed in the light most favorable to the defendant, could lead a rational factfinder to conclude that she was unaware that she had taken another’s property.