People v. Grayer, 2023 IL 128871

Defendant Santana Grayer was convicted of attempted vehicular hijacking following an incident in which he, while apparently intoxicated, attempted to forcibly take control of a Lyft driver's vehicle.
The incident occurred during a Lyft ride, where Grayer demanded to drive, threatened the driver, and took possession of the car keys at a gas station.
At trial, the defense argued that Grayer’s voluntary intoxication negated his ability to form the specific intent necessary for conviction.
The trial court found evidence of intoxication but concluded Grayer was aware of his surroundings and intended to hijack the vehicle.
The appellate court affirmed the conviction, holding that voluntary intoxication is no longer relevant to intent after statutory changes in 2002.
The Illinois Supreme Court affirmed, but clarified the role of voluntary intoxication in specific-intent crimes in Illinois law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether voluntary intoxication can negate specific intent for attempt crimes in Illinois	State argued voluntary intoxication is not a defense post-2002 and defendant formed intent	Grayer argued intoxication meant he was unable to form required specific intent	Voluntary intoxication is not an affirmative defense, but evidence may be relevant and admissible for intent; sufficient evidence of intent existed
Sufficiency of the evidence for specific intent to commit attempted vehicular hijacking	Defendant's actions and threats showed intent	Actions were mere drunken hyperbole; intent not shown because of intoxication	Circumstantial evidence sufficient to prove intent to commit offense beyond reasonable doubt
Relevance/admissibility of voluntary intoxication evidence post-2002 amendment	Not a defense; not relevant to intent	Amendment only removed as a defense, not as evidence on mental state	Evidence is admissible as relevant to intent but not an affirmative defense
Whether surveillance/video evidence supports intent	Video corroborates actions consistent with hijacking	Conduct at station consistent with wanting to go home, not theft	Finder of fact can infer intent from defendant’s conduct as shown on video; court affirms conviction

People v. Gutman, 2011 IL 110338 (statutory construction guidance)
People v. Terrell, 99 Ill. 2d 427 (specific intent may be inferred from conduct and circumstances)
Jackson v. Virginia, 443 U.S. 307 (reviewing sufficiency of evidence; due process requirement)
People v. Manion, 67 Ill. 2d 564 (right to present a defense on mental state)
In re Winship, 397 U.S. 358 (proof beyond reasonable doubt standard)
People v. Gonzalez, 239 Ill. 2d 471 (appellate review draws reasonable inferences in State’s favor)