United States v. Rainford.
No. 24-7022. 12/9/2025. E.D.Okla. Judge Federico. Murder in Indian Country—Involuntary Intoxication Affirmative Defense—Imperfect Defense of Another—Involuntary Manslaughter—Jury Instructions.
December 9, 2025
Rainford and Scroggins were friendly next-door neighbors. One morning, Rainford knocked on the back door of Scroggins’s house, and Scroggins went outside to show Rainford his rock garden. While Scroggins was turned around, Rainford shot him in the back and continued to shoot after Scroggins was on the ground. After firing 10 shots into Scroggins, Rainford stood over his lifeless body cursing at him. Scroggins’s stepson witnessed the event through a window, and his mother called police. Rainford was arrested and told the police that Scroggins had molested Rainford’s daughter, so he shot him to protect her. But Scroggins had never done anything inappropriate to Rainford’s daughter. Rainford was charged with murder in Indian Country; use, carry, brandish, and discharge of a firearm during and in relation to a crime of violence; and causing the death of a person while knowingly using, carrying, or brandishing a firearm during and in relation to a crime of violence. He stipulated to the fact that Scroggins was an Indian and the offense took place in Indian Country. At trial, Rainford raised an involuntary intoxication affirmative defense. This was based on his use, for several months before the shooting, of exceedingly high doses of Adderall, which he had been prescribed for attention deficit/hyperactivity disorder (ADHD). A Bureau of Prisons (BOP) psychologist determined that Rainford was competent to stand trial but was legally insane at the time of the shooting because of involuntary intoxication due to amphetamine-induced psychosis. The jury was instructed on involuntary intoxication but told that Rainford could not have been involuntarily intoxicated if he knew of Adderall’s possible intoxicating effects or if he had used illegal drugs while on Adderall. Rainford also requested an instruction on involuntary manslaughter for imperfect defense of another, but this instruction was denied. Rainford was convicted on all counts.
On appeal, Rainford argued that the jury was improperly instructed on the involuntary intoxication defense. He did not contest the part of the instructions explaining the basic elements of involuntary intoxication. But part of the instructions explained that an intoxicated condition produced involuntarily by innocent mistake is not present in, as relevant here, two situations: where there is illegal drug use and where knowledge exists of possible intoxicating effects. As to these disqualifiers, Rainford maintained that the instructions incorrectly stated the law and directed the jury to reject the defense for impermissible reasons. As to illegal drug use, Rainford argued that even if the jury found that he had used methamphetamine on the day of the shooting, he could still be considered involuntarily intoxicated by his Adderall prescription if that was found to be the cause of his psychosis. Illegal drug use by itself cannot be the basis for involuntary intoxication. Here, the relevant question is not whether Rainford used an illegal drug, but whether methamphetamine, rather than the prescribed Adderall, caused Rainford’s mental state when the shooting occurred. The district court’s instructions had no causal or temporal limit on illegal drugs as a disqualifier, so any illegal drug use over a period of years could be disqualifying. Thus, the district court erroneously told the jury that if Rainford had used any illegal drugs at any point in time, he could not be involuntary intoxicated.
As to knowledge of intoxicating effect, since all prescription drugs have some warnings, juries must be instructed to consider whether a defendant knew the risks of the specific type of intoxication that rendered him unable to appreciate the wrongfulness of his actions. That means Rainford had to have knowledge that Adderall ingestion causes psychosis with symptoms such as paranoia, delusions, and violent mood swings. The district court thus erred by removing this decision from the jury and instructing them that Rainford could not have been involuntarily intoxicated if the jury found he had any knowledge of Adderall’s possible intoxicating effects. Further, the error was not harmless, because the nuances of the involuntary intoxication instruction were central to the case’s outcome.
Rainford also contended that he was improperly denied an instruction on involuntary manslaughter based on the imperfect defense of another. He asserted that his delusions made him subjectively, though unreasonably, believe that Scroggins harmed his daughter. The district court denied an involuntary manslaughter instruction because it believed that the defense’s theory of imperfect defense of another required the jury to find involuntary intoxication. But voluntary intoxication can support a claim of imperfect defense of another if it shows that a defendant subjectively perceived a situation as different from reality. Rainford’s imperfect defense of another argument was thus cognizable not only if he was involuntarily intoxicated but also if he was voluntarily intoxicated. Based on Rainford’s statements, a reasonable jury could have concluded that Rainford subjectively, but unreasonably, believed he was acting in defense of his daughter. Accordingly, Rainford was entitled to an instruction on involuntary manslaughter.
Rainford additionally asserted that the district court abused its discretion by giving a limiting instruction to the jury after the defense’s closing argument, maintaining that the instruction effectively labeled defense counsel a liar in front of the jury. All parties acknowledged that during his closing argument, defense counsel violated the court’s earlier caution to not refer to a witness as the court’s expert. Because the Tenth Circuit remanded for a new trial, it did not consider or find whether the district court’s specific instruction was an abuse of discretion. But it pointed out that while a jury instruction was warranted to avoid confusion, it is potentially problematic for a district court to tell the jury, as it did here, that an attorney has misrepresented a fact, violated a pretrial order, and said something untrue.
The convictions were reversed and the case was remanded for a new trial.