A diabetic man convicted of trying to kill his wife won a chance for a new trial Monday when the Colorado Supreme Court ruled that low blood sugar can cause involuntary intoxication and leave someone incapable of following the law.
The ruling said that under certain conditions, low blood sugar, or hypoglycemia, can meet the legal definition of involuntary intoxication as a defense against any crime. It was the first time the court had been presented with that question.
Steve David Garcia Jr., an insulin-dependent diabetic, was convicted of second-degree attempted murder and first-degree assault in a 1999 attack on his wife.
The Supreme Court ruled that the trial judge was wrong when he limited Garcia’s ability to use involuntary intoxication from hypoglycemia as a defense.
On a 4-3 vote, the justices said Garcia has to be given another chance to prove he was involuntarily intoxicated, but they left it up to the lower court judge to determine whether he should get a new trial.
The dissenting justices agreed that insulin-induced hypoglycemia could result in involuntary intoxication but said Garcia’s low blood sugar was a result of his own actions. He had injected himself with a large dose of insulin on the day of the attack in anticipation of eating cake and ice cream at his daughter’s birthday party.
Prosecutors said Garcia hit his wife on the head with a hammer and ran over her with a van in July 1999, three days after she told him she wanted a divorce. She suffered a fractured skull and other injuries.
During his trial, Garcia didn’t dispute that he attacked his wife but said he wasn’t legally responsible because of hypoglycemia. Doctors testified that symptoms of the condition can include a loss of motor skills and an altered mental state that can “prevent rational thinking, planning, deliberation and even appreciation of what (one is) doing.”
