State v. Eager., 398 P.3d 756

Samuel Eager was charged with second-degree assault after a 2013 attack on a 79‑year‑old man; he elected a bench trial and raised lack of penal responsibility due to mental disease, disorder, or defect (psychosis).
A court‑appointed three‑member examiner panel produced split opinions: Dr. Gitter (defense) concluded Eager was psychotic and substantially impaired; Drs. Jacobs and Wagner (State rebuttal) concluded capacities were not substantially impaired and attributed symptoms to prescription withdrawal and marijuana use.
The circuit court found Eager guilty, concluding his psychosis was "self‑induced" by refusal to take prescribed medication and marijuana use, and sentenced him to five years' imprisonment; the ICA affirmed.
On certiorari the Hawai‘i Supreme Court addressed (1) whether Dr. Wagner improperly bolstered Dr. Jacobs' opinion and (2) whether the trial court erred treating failure to take prescribed medication as "self‑induced intoxication" that negates the HRS § 704‑400 defense.
The Court held Dr. Wagner's testimony was admissible and did not improperly bolster Dr. Jacobs, but concluded the circuit court plainly erred by treating failure to take medication as "introducing" a substance under HRS § 702‑230, vacated the convictions, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility: Did Dr. Wagner impermissibly bolster Dr. Jacobs' opinion?	State: Dr. Wagner’s responses about Dr. Jacobs’ report aided factfinding and were proper rebuttal/context.	Eager: Dr. Wagner considered Dr. Jacobs’ opinion, improperly bolstering credibility in violation of HRS § 704‑404.	Admissible — Wagner did not testify to Jacobs’ credibility; court did not abuse discretion.
Self‑induced intoxication: Can failure to take prescribed medication qualify as "self‑induced intoxication" under HRS § 702‑230?	State: Eager’s volitional failure to take meds (and marijuana use) produced psychosis; volition should bar the HRS § 704‑400 defense.	Eager: Failure to take medication is not "introducing" a substance into the body and thus is not self‑induced intoxication under the statute.	Held for Eager — failing to take medication is not "introducing" a substance; circuit court plainly erred in treating non‑use as self‑induced intoxication; vacated and remanded.

State v. Freitas, 62 Haw. 17, 608 P.2d 408 (1980) (self‑induced intoxication is not a disability beyond the defendant's control and may not excuse responsibility)
Commonwealth v. Shin, 16 N.E.3d 1122 (Mass. App. Ct. 2014) (trial court erred in using failure to take prescribed medication to negate lack‑of‑criminal‑responsibility defense)
State v. Souza, 72 Haw. 246, 813 P.2d 1384 (1991) (purpose of HRS § 702‑230 is to bar defense for defendants who voluntarily become intoxicated)
State v. Batangan, 71 Haw. 522, 799 P.2d 48 (1990) (expert testimony may indirectly affect credibility but is admissible unless unduly prejudicial)
State v. Calara, [citation="132 Hawai'i 391, 322 P.3d 931"] (2014) (examples of improper bolstering when a witness implies credibility of another)
State v. Ryan, [citation="112 Hawai'i 136, 144 P.3d 584"] (2006) (expert testimony improperly implied belief in complaining witness)
State v. Morris, 72 Haw. 527, 825 P.2d 1051 (1992) (expert testimony that clearly implied belief in a witness is inadmissible)