Todd Lee Harnden v. State, 378 P.3d 611

On Aug. 14, 2014, Todd Lee Harnden drank vodka, went to the Laramie Walmart to exchange a propane tank, became impatient, and went into the garden center.
Harnden opened a bottle of lighter fluid, poured it on a bag of charcoal, and ignited it; firefighters extinguished the blaze and he was later arrested and admitted starting the fire because he was upset.
Harnden was tried twice (first trial hung); at the second trial a jury convicted him of first-degree arson and the court sentenced him to 10–18 years' imprisonment.
First-degree arson under Wyoming law requires maliciously starting a fire with intent to destroy or damage an occupied structure.
Harnden argued on appeal that his intoxication prevented formation of the specific intent required for first-degree arson, so at most he should have been guilty of a lesser degree.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to convict Harnden of first-degree arson	State: circumstantial and direct evidence (choice of accelerant, pouring fluid, ignition, admissions, recorded phone call, lucid behavior) supports malicious intent	Harnden: self-induced intoxication prevented formation of the specific intent required for first-degree arson	Affirmed: jury could reasonably find malicious intent despite intoxication and convict of first-degree arson

Keats v. State, 64 P.3d 104 (clarifies malice in first-degree arson encompasses acting without legal justification or with ill will)
Hankinson v. State, 47 P.3d 623 (jury may infer specific intent from a defendant's conduct despite heavy intoxication)
Pena v. State, 361 P.3d 862 (circumstantial evidence, including words and conduct, can establish intent)
Faubion v. State, 233 P.3d 926 (standard for reviewing sufficiency of the evidence)
Andersen v. State, 330 P.3d 256 (State's evidence accepted as true and given favorable inferences on review)
Toth v. State, 353 P.3d 696 (same principle regarding appellate sufficiency review)