People v. Grant

Brief Fact Summary.

Grant (Defendant) had epilepsy and would suffer from seizures. He was convicted of attempting to assault a police officer making an arrest and appealed, arguing that the jury was not instructed that his actions must be voluntary.

Synopsis of Rule of Law.

An individual is not criminally liable for actions over which he has no conscious control.

Facts.

Defendant was diagnosed with epilepsy. The condition caused seizures and violent outbursts. Defendant was outside of a tavern while a police officer was arresting another individual. Defendant threw himself at the officer in an attempt to keep him from arresting the other individual. Defendant was arrested and then suffered a serious seizure requiring hospitalization. Defendant argued at trial that the entire incident was the result of his epilepsy. The court instructed the members on insanity, but did not instruct on automatic behavior. Defendant was convicted, and appealed.

Issue.

Is an individual criminally liable for actions over which he has no conscious control?

Held.

(Reardon, J.) No. An individual is not criminally liable for actions over which he has no conscious control. Automatic acts are not the same thing as insanity. While insanity keeps a person from understanding the criminal nature of his behavior, automatism prevents a person from controlling his behavior, even though he understands its criminal nature. An automatic act is involuntary and the jury should have been instructed to that effect. Reversed.

Discussion.

Insanity pertains to the mens rea requirement of an offense. Automatism pertains to the actus reus requirement of an offense. If the conscious mind loses control over the actions of the body, then the act is involuntary and the individual is not criminally responsible.