State v. Brennauer

Summary

The court held that the statutory exclusion for temporary conditions proximately caused by voluntary intoxication codifies the distinction between temporary intoxication and settled insanity; it does not eliminate an insanity defense based on a mental disease or defect developed through prolonged substance abuse. Although the instruction on temporary intoxication correctly stated the law in isolation, the instructions were plainly erroneous because they failed to explain settled insanity in light of the State’s evidence and argument. The court reversed, vacated the convictions and sentences, and remanded for a new trial.