Martin v. State 31 Ala. App. 334, 12 So.2d 427 (1944) Martin was at home, drunk and belligerent. The police came and arrested him. They tossed him in the back of the police car and drove him to the police station. Along the way, Martin continued to be drunk and belligerent. The prosecutor charged Martin with being publicly intoxicated. The Trial Court convicted Martin. He appealed. The Appellate Court overturned the conviction. The Appellate Court found that Martin was not voluntarily in public. He was only there because the police forcibly carried him there. The basic point of this case is that in order to be culpable, there is usually a requirement that the actions be voluntary. Involuntariness is an actus reus defense, which means that the person never intended to do the act (like they were sleepwalking or having an epileptic attack). There is also a mens rea defense, which means that the person intended to do the act, but had a good excuse (like they were under duress, were insane, or the act was an accident). In this case, Martin never intended to be in public. He was carried there against his will, therefore it's a actus reus defense.