City of Missoula v. Paffhausen
Annotate this CaseShortly after Defendant was charged with DUI, she notified the police department that she believed she had been given a "date rape" drug that caused her impairment. Before trial commenced, Defendant claimed she would assert the involuntary intoxication defense to show she did not commit a voluntary act by driving. The municipal court granted the City's motion to prevent Defendant from claiming involuntary intoxication as a defense and from calling witnesses about the use of "date rape" drugs in the City. The district court affirmed, concluding that involuntary intoxication can only be used where the mental state of the defendant is an element of the crime. Defendant appealed, contending that the lower court erred by failing to apply the voluntary act element of Montana's DUI statute. The Supreme Court reversed and remanded, holding (1) the lower court erred by precluding Defendant from raising automatism as an affirmative defense to the DUI charge; and (2) if Defendant was able to lay the proper foundation, she could elicit from certain law enforcement officers evidence regarding their personal knowledge, opinions, and statements regarding whether Defendant was unknowingly drugged, and voluntarily drove a vehicle.
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