State v. RT, 16 A.3d 365

Defendant, Robert Trout, was charged with multiple sexual offenses against his nephew Larry, spanning 1997–2003.
Before trial, statements and Larry’s interview were admitted; defendant denied abuse and claimed police coercion.
During trial, defense denied intoxication; State introduced evidence of drinking and defendant’s statements referencing alcohol.
The trial court sua sponte instructed voluntary intoxication as a defense, despite defense objection that it was unwarranted.
Appellate Division reversed, finding the instruction inappropriate and prejudicial, remanding for a new trial.
State appealed; the Supreme Court, in a divided decision, affirmed the Appellate Division’s reversal, with Justice LONG concurring in part.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the voluntary intoxication instruction was properly sua sponte.	R.T. argues record clearly indicated intoxication as a defense; instruction warranted.	Intoxication was not an appropriate or supported defense; instruction prejudiced defense strategy.	Not warranted; improper sua sponte instruction.
Whether the evidence supported a voluntary intoxication defense for six years of alleged conduct.	Evidence of drinking over time could negate requisite mental state.	No proof faculties were prostrated on each event; no basis to instruct.	Evidence did not clearly show prostration on each offense; no basis for instruction.
Whether giving the intoxication instruction prejudiced the defendant’s trial.	Instruction helped jurors assess credibility given defendant’s statements.	Instruction invaded defense strategy and suggested guilt; prejudicial.	Prejudicial impact found; error not harmless beyond reasonable doubt.

State v. Cameron, 104 N.J. 42 (1986) (so-defined self-induced intoxication defenses to negate intent)
State v. Mauricio, 117 N.J. 402 (1990) (factors for assessing prostration of faculties and charge appropriateness)
State v. Denofa, 187 N.J. 24 (2006) (clearly indicated standard for charging lesser-included offenses)
State v. Garron, 177 N.J. 147 (2003) (caution on unanticipated instructions and need to record reasons when departing from rules)
State v. Perry, 124 N.J. 128 (1991) (defense strategy considerations limit coercive instruction imposition)