State v. Brennauer

Summary

The court held that the statutory exclusion for a temporary condition proximately caused by voluntary intoxication codified existing law and did not eliminate the settled-insanity distinction. Because the evidence involved long-term substance use and the jury was instructed only on temporary intoxication without being instructed that substance-related settled or fixed insanity could support the defense, the instructions created a prejudicial risk of confusion. The court noticed plain error, reversed the judgment, vacated the convictions and sentences, and remanded for a new trial.