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State v. Caddell

Citation. 448 Fed. Appx. 376 (4th Cir. 2011) [2011 BL 257060]
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Brief Fact Summary.

Appellant argued that he was unconscious when he committed the crimes he was charged with.

Synopsis of Rule of Law.

Unconsciousness or automatism is a complete defense to a criminal charge and is an affirmative defense that the burden is with the defendant to establish this defense.


Appellant was charged with kidnapping. Victim, a 14 year-old girl, testified that Appellant forced her into a car, beat her and attempted to rape her and then ran away. Appellant testified that he remembered nothing about the events of that day. A psychiatrist testified that Appellant had a sociopathic personality. Appellant was convicted and sentenced to life in prison. Appellant argued that he was not guilty by reason of insanity, specifically that he was ‘unconscious’ during the events in question.


Whether there exists the defense of unconsciousness as a complete defense to a criminal charge.


Although the trial judge was in error, it was not prejudicial and does not afford a basis for a new trial.
The defense of unconsciousness is separate from the defense of insanity and the result is that if the defendant is found to be unconscious, he can be found not guilty and is not subject to commitment in a mental hospital.

The burden of proving the defense of proving unconsciousness rests with the defendant.


The dissent concurred on the result but dissented on the reasoning and allowance of unconsciousness of a defense. The dissent argued that unconscious actions are not voluntary and thus there is no burden on the defendant to prove unconsciousness as a defense, rather the burden is on the State to prove that the acts were voluntary that constituted the crime. The dissent concluded that unconsciousness is never an affirmative defense.


The Court first overruled one prior case that ruled that unconsciousness was not an affirmative defense. The Court next analyzed how the defendant could present such a defense. It concluded that the burden would rest on the defendant to present evidence of unconsciousness through medical testimony or alternative means.

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