Jorida Davidson v. United States

Summary

The District of Columbia Court of Appeals affirmed Jorida Davidson’s voluntary manslaughter conviction arising from a fatal vehicle-pedestrian collision. The court held that voluntary intoxication is not a defense to voluntary manslaughter and rejected Davidson’s argument that Comber v. United States changed that longstanding rule. The court also concluded that the evidence was sufficient and that the trial court did not improperly limit closing argument.

Holdings

1. Voluntary intoxication is not a defense to voluntary manslaughter in the District of Columbia; accordingly, the trial court properly refused to give the requested instruction.
2. The evidence was sufficient for a reasonable jury to find that Davidson consciously disregarded an extreme risk of death or serious bodily injury to another person.
3. The trial court did not abuse its discretion by precluding Davidson from comparing the evidence presented at the current trial with evidence presented at the first trial.

Questions Presented

1. Whether voluntary intoxication is a defense to voluntary manslaughter under District of Columbia law and therefore required a jury instruction.
2. Whether the evidence was sufficient for a reasonable jury to find that Davidson acted with conscious disregard of an extreme risk of death or serious bodily injury.
3. Whether the trial court improperly limited Davidson's closing argument by preventing comparison of the evidence in the present trial with evidence from her first trial.

Disposition

affirmed