Ronald King v. Commonwealth of Kentucky

Summary

The court held that the evidence was sufficient to require a jury instruction on voluntary intoxication because it could support a reasonable inference that King was too intoxicated to form the intent required for some charged offenses. The omission of that instruction was reversible error only as to the intentional second-degree assault conviction; it did not affect the convictions based on wanton or reckless mental states, including third-degree arson. The court therefore reversed the second-degree assault conviction and sentence, affirmed the remaining convictions, and remanded for further proceedings. On remand, the trial court may reconsider the admissibility of King's blood-analysis report if he again seeks to introduce it.