In Re: the People of the State of Colorado v. Paul Lesley Voth

Summary

The court made absolute its rule to show cause and vacated the trial court's order permitting Paul Voth to assert involuntary intoxication based on a viral infection. It held that a virus is not a "substance" under the involuntary-intoxication statute and that the trial court therefore abused its discretion. The court also clarified that Colorado's insanity defense may apply to a temporary episode of insanity if the defendant was legally insane when the offense occurred and satisfies the other statutory requirements.