Coley & Ors v R

Coley & Ors v R

Voluntary intoxication, even if resulting in psychotic episodes or mental disorder, does not amount to insanity or automatism in law; such conditions are not classified as disease of the mind under M’Naghten rules. Automatism is not available where the defendant's actions are voluntary or the condition is self-induced. Recklessness is not excused by mental disorder induced by past voluntary intoxication unless the defendant was actually aware of the risk.

Parties
Appellant: Scott Coley; Respondent: The Queen; Appellant: Colin McGhee; Appellant: Darren Harris
Jurisdiction
England and Wales
Judgment Date
12 March 2013
Procedural Posture
Criminal Appeal / Judgment
Outcome
Coley and McGhee: appeals against conviction dismissed; Harris: appeal against conviction allowed, conviction quashed, no retrial ordered.
Legal Topics
Insanity, Automatism, Voluntary Intoxication, Specific Intent, Recklessness
Criminal Law Insanity Automatism Voluntary Intoxication Specific Intent Recklessness

Case Brief

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Parties

Scott Coley

Appellant

The Queen

Respondent

Colin McGhee

Appellant

Darren Harris

Appellant

Procedural Posture

Criminal Appeal / Judgment

Legal Issues

  1. 1 Whether insanity or automatism defences should have been left to the jury in cases involving voluntary intoxication and mental disorder.
  2. 2 Whether voluntary intoxication can amount to a disease of the mind under M’Naghten rules.
  3. 3 Application of the law of recklessness in the context of mental disorder induced by past voluntary intoxication.

Ratio Decidendi

Voluntary intoxication, even if resulting in psychotic episodes or mental disorder, does not amount to insanity or automatism in law; such conditions are not classified as disease of the mind under M’Naghten rules. Automatism is not available where the defendant's actions are voluntary or the condition is self-induced. Recklessness is not excused by mental disorder induced by past voluntary intoxication unless the defendant was actually aware of the risk.

Court Disposition

Coley and McGhee: appeals against conviction dismissed; Harris: appeal against conviction allowed, conviction quashed, no retrial ordered.

Orders

  • Coley: sentence reduced from 18 years to 15 years youth custody.
  • McGhee: conviction upheld, no change to sentence.