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Alabama Court of Appeals - 17 So. 2d 427
tl;dr:
Man arrested while drunk in his home and brought onto highway by police. Cant be held liable for public drunkenness because public appearance was not voluntaryVideo Summary
Case Summary
In the 1944 case of Martin v. State, the Alabama Court of Appeals overturned a conviction for being intoxicated on a public road. The case involved Martin, who was arrested at his home and forcefully taken to a public road by police officers. There, he used loud and inappropriate language, leading to his charge and conviction for being drunk in public. Martin appealed, and the case set a precedent that a crime's guilty act must be voluntary.
The court determined that Martin's presence on the road wasn't voluntary, but instead forced by the police. As a result, he couldn't be guilty of being drunk in public, since the law required the act to be voluntary. The court believed that individuals shouldn't be held criminally responsible for actions beyond their control, and Martin's behavior on the road was not by his own choice. Thus, the court reversed the conviction and sent the case back for further review.
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The appellant was convicted of being drunk on a public highway, but the arresting officers took him from his home to the highway where he allegedly committed the offense. However, the statute requires a voluntary appearance in a public place, and the court has ruled that an accusation of drunkenness cannot be established if the accused was involuntarily and forcibly taken to the public place by the arresting officer. The lower court erred in convicting the appellant under these circumstances. The conviction was found to be erroneous and contrary to the prevailing rule. The evidence presented was insufficient to sustain a legal conviction. Therefore, the judgment of the trial court was reversed, and the appellant was discharged. The original opinion of affirmance was withdrawn.
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