Farmer v. Texas (Original)Annotate this Case
Appellant Kody William Farmer was convicted of driving while intoxicated and sentenced to 90 days' confinement and to pay a $200 fine. The question on appeal to the Supreme Court in this case centered on whether there was sufficient evidence introduced at trial to entitle Appellant to a jury-charge instruction on voluntariness. The court of appeals held that Appellant was entitled to a voluntariness instruction. Appellant suffered from chronic back pain due to a work-related injury. As a result, he had taken different medications on and off for more than 10 years, including Ultram, (a painkiller), and Soma (a muscle relaxer). Four days prior to the incidents at issue here, Appellant was prescribed Ambien (a sleep aid), for the first time to assist with insomnia. On the night he was pulled over, appellant stated to police that he did not remember taking any of his medications. At trial, Appellant's wife testified that she did not remember seeing Appellant take his medication that morning, but she remembered that "the Ambien I laid out for the night that was on the other side of [the] microwave was gone." She also testified that she was a hundred percent certain that "he took what I had laid out." Appellant appealed his conviction, and the court reversed Appellant's conviction and remanded to the trial court. It held that the facts of this case were "most closely akin to an involuntary act because the evidence suggests that although Farmer voluntarily took the pills laid out for him by his wife, he involuntarily took the Ambien pill because of his wife's act." Upon review, the Supreme Court concluded that Appellant's action in taking the Ambien pill was a voluntary act because Appellant, of his own volition, picked up and ingested the Ambien pill. Because no other evidence at trial raised an issue of Appellant's voluntariness in taking that medication, the trial court properly denied Appellant's request. As a result, the court of appeals erred when it reversed the judgment of the trial court.