State v. EagerAnnotate this Case
A defendant’s failure to take prescription medication does not constitute self-induced intoxication under Haw. Rev. Stat. 702-230, which precludes the defendant from relying on the defense of lack of penal responsibility due to a physical or mental disease, disorder or defect.
Defendant, who was charged with assault in the second degree, presented the defense of lack of criminal responsibility as a result of disease, disorder, or defect. The circuit court found Defendant guilty, concluding that any disease, disorder, or defect Defendant was experiencing at the time of the assault was self-induced and the product of Defendant’s refusal to take his prescribed medication and his use of marijuana. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction, holding that the circuit court’s conclusion that Defendant’s failure to take his medication caused his psychotic behavior was inconsistent with the plain language of section 702-230, which requires the introduction of substances into the body.