involuntary intoxication defense (Illinois) · Go Syfert
← Illinois issues

involuntary intoxication defense in Illinois

13 Illinois opinions name it 2 courts 1987–2026 4 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
People v. Harigreen
ill · 2006 · cited in 7 Illinois opinions naming this issue, 2011–2026
2 sentences

2026See infra ¶ 99 (citing Hari, 218 Ill. 2d at 297 ). ¶ 61 The paragraph the special concurrence quotes was the Hari court’s response to the State’s argument that any error in the court’s failure to give the involuntary intoxication instruction was harmless.

2026See People v. Hari, 218 Ill. 2d 275, 278 (2006) (recognizing, for the first time, that an involuntary intoxication defense may be based on an unexpected and unwarned side effect of prescribed medication).

67
People v. Albertsgreen
illappct · 2008 · cited in 3 Illinois opinions naming this issue, 2011–2020
2 sentences

2011Thus, the Hari holding does not support the proposition that mixing prescription medication with illegal drugs gives rise to the involuntary intoxication defense. ¶ 24 Defendant relies on the Fourth District's holding in People v. Alberts, 383 Ill.App.3d 374 , 322 Ill.Dec. 289 , 890 N.E.2d 1208 (2008), to support his position that the involuntary intoxication defense applies to his case.

2011Thus, the Hari holding does not support the proposition that mixing prescription medication with illegal drugs gives rise to the involuntary intoxication defense. ¶ 24 Defendant relies on the Fourth District's holding in People v. Alberts, 383 Ill.App.3d 374 , 322 Ill.Dec. 289 , 890 N.E.2d 1208 (2008), to support his position that the involuntary intoxication defense applies to his case.

13
People v. Rogersgreen
ill · 1988 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011People v. Rogers, 123 Ill.2d 487, 508 , 123 Ill.Dec. 963 , 528 N.E.2d 667 (1988).

2011People v. Rogers, 123 Ill.2d 487, 508 , 123 Ill.Dec. 963 , 528 N.E.2d 667 (1988).

12
People v. Talianigreen
ill · 2021 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See Taliani, 2021 IL 125891, ¶ 70 (an involuntarily intoxicated defendant lacks the substantial capacity to “either appreciate the criminality of his conduct or conform his conduct to the law” (emphases 13 added)).

11
People v. Palmergreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025“It is fundamental, however, that the precedential scope of a decision is limited to the facts before the court.” People v. Palmer, 104 Ill. 2d 340, 345-36 (1984).

11
Schlup v. Delored
scotus · 1995 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020“Stated differently, leave of court should be granted when the petitioner’s supporting documentation raises the probability that ‘it is more likely than not that no reasonable juror would have convicted him in the light of the new evidence.’ ” Id. (quoting Schlup v. Delo, 513 U.S. 298, 327 (1995)). ¶ 27 Here, the allegations in the petition and the supporting documentation may have shown that defendant suffered from unwarned side effects of prescription medication at the time of the offense such that the “involuntarily produced” component of the involuntary intoxication defense was satisfied.

11
People v. Hallgreen
ill · 2005 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020People v. Hall, 217 Ill. 2d 324, 334 (2005). ¶ 41 With these standards in mind, we now turn to the State’s initial argument. ¶ 42 A. TIMELINESS OF DEFENDANT’S PETITION ¶ 43 In People v. Hari, 218 Ill. 2d 275, 278 (2006), our supreme court held, for the first time, that an involuntary-intoxication defense can be based on “an unexpected adverse side effect of a prescription drug that was unwarned by the prescribing doctor, the PDR [(Physicians’ Desk Reference)], or the package insert.” Id. at 292 .

11
People v. Coxgreen
ill · 2001 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014People v. Cox, 195 Ill. 2d 378, 387 (2001). ¶ 73 The Illinois statute codifying the involuntary intoxication defense provides: “A person who is in an intoxicated or drugged condition is criminally responsible for conduct unless such condition is involuntarily produced and deprives him of substantial capacity either to appreciate the criminality of his conduct or to conform his conduct to the requirements of law.” 720 ILCS 5/6-3 (West 2006). ¶ 74 Involuntary intoxication is an affirmative defense that exonerates an accused if the trier of fact believes the elements of the defense have been met.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
People v. Brumfield green
illappct · 1979
2 sentences

2011Thus, the supreme court in Hari did not overrule Rogers, Downey, Gerrior, Walker, and Larry with respect to their holdings that a defendant who knowingly ingests an illegal substance cannot raise the involuntary intoxication defense. ¶ 26 Second, defendant claims that the Fifth District's decision in People v. Brumfield, 72 Ill.App.3d 107 , 28 Ill.Dec. 422 , 390 N.E.2d 589 (1979), demonstrates that the involuntary intoxication defense is not automatically barred where illegal drugs are voluntarily ingested.

2011Thus, the supreme court in Hari did not overrule Rogers, Downey, Gerrior, Walker, and Larry with respect to their holdings that a defendant who knowingly ingests an illegal substance cannot raise the involuntary intoxication defense. ¶ 26 Second, defendant claims that the Fifth District's decision in People v. Brumfield, 72 Ill.App.3d 107 , 28 Ill.Dec. 422 , 390 N.E.2d 589 (1979), demonstrates that the involuntary intoxication defense is not automatically barred where illegal drugs are voluntarily ingested.

31987–2011
People v. Teschner green
illappct · 1979
2 sentences

2009While involuntary intoxication is a proper defense to most crimes [citation], to allow such a defense to a charge of driving while intoxicated would result in the inadequate protection of [the] public from the dangers of intoxicated drivers." Teschner, 76 Ill.App.3d at 126 , 31 Ill.

2009While involuntary intoxication is a proper defense to most crimes [citation], to allow such a defense to a charge of driving while intoxicated would result in the inadequate protection of [the] public from the dangers of intoxicated drivers.” Teschner, 76 Ill.

12009–2009
People v. White green
illappct · 1970
1 sentence

1992(People v. White, 131 Ill.

11992–1992
Strickland v. Washington green
scotus · 1984
1 sentence

1987The performance of defendant’s trial counsel is tested by the standards adopted by the United States Supreme Court in Strickland v. Washington (1984), 446 U.S. 668 , 80 L.

11987–1987
People v. Banks green
ill · 1979
2 sentences

1987(See People v. Banks (1979), 75 Ill. 2d 383 , 388 N.E.2d 1244 .) While it appears that these defenses were contemplated by defendant’s trial counsel, it is apparent that, as the trial developed, only an argument for an involuntary intoxication defense might have a reasonable possibility of success.

1987(See People v. Banks (1979), 75 Ill. 2d 383 , 388 N.E.2d 1244 .) While it appears that these defenses were contemplated by defendant’s trial counsel, it is apparent that, as the trial developed, only an argument for an involuntary intoxication defense might have a reasonable possibility of success.

11987–1987

Statutes the citing opinions construe

IL § 720 ILCS 5/6-3 (8) IL § 725 ILCS 5/122-1 (4) IL § 720 ILCS 5/9-1 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 13 (1987–2026) FL 12 (1997–2017) TX 10 (1994–2015) PA 9 (1990–2026) WI 9 (1976–2026) MO 7 (1987–2024) CA 7 (1990–2025) IN 7 (2000–2014) CO 5 (2002–2026) NJ 5 (1990–2013) AZ 4 (2002–2025) MN 3 (2010–2024) KS 3 (2020–2024) OH 3 (2022–2026) WA 3 (2014–2018) NY 2 (2006–2019) AK 2 (2010–2021) NC 2 (2021–2021) HI 2 (2012–2012)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check