Brief Fact Summary. The Defendant, David McClain, filed this interlocutory appeal (appeal from an order that is not final) to challenge the trial court’s grant of the state’s motion in limine excluding expert testimony on the defense of automatism.
Synopsis of Rule of Law. Automatism and insanity are separate defenses. Evidence of automatism bears on the voluntariness of the Defendant’s actions and is admissible without pleading an insanity defense.
Issue. Did the trial court err in excluding expert testimony on sleep disorders and dissociative states after the Defendant withdrew his insanity defense?
Held. Yes. A person commits a crime if he voluntarily engages in conduct violating the statute defining the offense. Automatism bears on the voluntariness of one’s actions. The Defendant claimed that he was unable to from criminal intent due to an automatistic state of mind from sleep deprivation precluding voluntary behavior. Importantly, this claim does not state or imply that automatism is a mental disease or defect, thereby invoking the insanity defense. Thus, automatism and insanity are separate defenses. The Defendant may present evidence of automatism despite not giving notice of the defense.
Discussion. Automatism is a partial defense to criminal liability. Asserting the defense can only negate the voluntariness element of the offense.