Gould v. State
Gould v. State, 579 P.2d 535 (Alaska 1978), is a leading case rejecting the use of narcotics addiction evidence as showing a generalized "motive" to steal.
There the court focused primarily on what it described as the "absence of any 'affirmative link' between the robbery and Gould's alleged heroin addiction." Id. at 539.
It concluded that the argument premised on "reasoning that because Gould was unemployed and had a $ 300 a day heroin habit, he had to commit the robbery to support his habit . . ., was too attenuated and possessing 'too many gaps' to show motive and thus the identity of the robber." Ibid.
In Gould v. State, Gould was on trial for armed robbery. The State introduced evidence of Gould's heroin addiction to show a potential motive, and the superior court instructed the jury that it could only consider the evidence for that purpose.
Although the State presented several eyewitnesses who identified Gould as the robber, Gould called several witnesses to present an alibi defense.
The supreme court concluded that it could not say with fair assurance that the evidence regarding the defendant's drug addiction did not have a substantial impact on the jury.