R v Coley; R v McGhee; R v Harris
A defendant who becomes violent after voluntary intoxication cannot rely on automatism, and the distinction between insanity and automatism depends on the cause of the condition.
Facts
In three appeals heard together, defendants had committed violent offences after taking drink or drugs. In Coley, a 17 year old boy who had been playing a violent video game stabbed his neighbour after drinking heavily, and claimed to have been in a psychotic state or blackout. In the other cases, the defendants relied on intoxication in relation to self defence and attempted murder.
Legal principle
The Court of Appeal dismissed the appeals. Hughes LJ said that automatism requires a complete destruction of voluntary control, and that a defendant whose condition was caused by voluntary intoxication could not rely on automatism, because of the rule in Majewski. In Coley's case, any abnormal mental state was the result of voluntary intoxication, and he had acted in a purposeful way, so the defences of insanity and automatism were not available. The court also confirmed that a defendant cannot rely on a mistaken belief in the need to use force that was caused by voluntary intoxication.
Related cases on defences: insanity, automatism and intoxication
- Attorney General for Northern Ireland v Gallagher [1963] AC 349
- Attorney General's Reference (No 2 of 1992) [1994] QB 91
- DPP v Majewski [1977] AC 443
- Hill v Baxter [1958] 1 QB 277
- M'Naghten's Case (1843) 10 Cl & F 200
- R v Bailey [1983] 1 WLR 760
- R v Burgess [1991] 2 QB 92
- R v Hardie [1985] 1 WLR 64
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