People v. Soto, 231 Cal. Rptr. 3d 732

Defendant Juaquin Garcia Soto, after days of methamphetamine use and drinking, entered an apartment, engaged in a knife fight with Israel Ramirez, and Ramirez died of stab wounds.
Soto claimed self‑defense and alternatively imperfect (unreasonable) self‑defense reducing murder to voluntary manslaughter; he also presented expert testimony on methamphetamine‑induced psychosis and intoxication effects.
Trial court gave CALCRIM No. 625 limiting voluntary‑intoxication evidence to negating specific intent, premeditation/deliberation, express malice, or unconsciousness, and barred the jury from using intoxication evidence to assess whether Soto actually believed he needed to act in self‑defense.
Jury acquitted first‑degree murder but convicted Soto of second‑degree murder and first‑degree burglary; Court of Appeal held the intoxication limitation was error (but harmless) and affirmed.
Supreme Court granted review to decide whether Penal Code § 29.4(b) permits voluntary‑intoxication evidence to negate a defendant’s actual (but unreasonable) belief in the need for self‑defense.
The Supreme Court concluded § 29.4(b) does not allow such evidence on the self‑defense belief question and affirmed the Court of Appeal’s judgment (disapproving the portion holding error).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Penal Code § 29.4(b) permits admission of voluntary‑intoxication evidence to show the defendant actually (but unreasonably) believed deadly force was necessary (i.e., to negate the ‘unlawful’ component of express malice / support imperfect self‑defense).	State: § 29.4(b) validly limits intoxication evidence; it does not allow intoxication to negate implied malice or conscious disregard, and the trial instruction was correct.	Soto: § 29.4(b) expressly admits intoxication evidence as to whether the defendant “harbored express malice,” and because express malice requires intent to kill unlawfully, intoxication evidence may negate the defendant’s belief that killing was unlawful (i.e., permit imperfect self‑defense).	The court held § 29.4(b) does not permit voluntary‑intoxication evidence to negate a defendant’s actual (but unreasonable) belief in the need for self‑defense; CALCRIM 625 was correct.

In re Christian S., 7 Cal.4th 768 (1994) (recognizes that an honest but unreasonable belief in the need for self‑defense negates malice and reduces murder to manslaughter)
People v. Whitfield, 7 Cal.4th 437 (1994) (held voluntary intoxication could negate malice before legislative amendment; Justice Mosk’s dissent argued otherwise)
People v. Mendoza, 18 Cal.4th 1114 (1998) (interpreted former §22 regarding specific intent and aider‑and‑abettor liability)
Montana v. Egelhoff, 518 U.S. 37 (1996) (upheld state rule barring voluntary‑intoxication evidence to negate mens rea against federal due process challenge)
People v. Elmore, 59 Cal.4th 121 (2014) (explains that an actual but unreasonable belief in need for self‑defense negates malice)
People v. Atkins, 25 Cal.4th 76 (2001) (rejects using intoxication to negate arson mental state; discusses Mendoza’s narrow scope)
People v. Timms, 151 Cal.App.4th 1292 (2007) (Court of Appeal upholding §29.4 against due process challenge and refusing intoxication to negate implied malice)
People v. Martin, 78 Cal.App.4th 1107 (2000) (same conclusion upholding statutory limits on intoxication evidence)