State v. Caddell
1975 N.C. LEXIS 1120, 215 S.E.2d 348, 287 N.C. 266 (1975)
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Rule of Law:
Unconsciousness, or automatism, is a complete, affirmative defense to a criminal charge, separate from the defense of insanity, and the burden rests upon the defendant to establish this defense to the satisfaction of the jury.
Facts:
- An assailant seized Catherine Sutton at her home in Guilford County and forcibly put her into an automobile.
- The assailant drove Sutton approximately three miles to a wooded area in Randolph County.
- In the wooded area, the assailant beat and attempted to rape Sutton.
- The entire sequence of events, from the abduction to the end of the assault, lasted approximately 20 minutes.
- Willis Tony Caddell was identified as the assailant.
- Caddell asserted that he was unconscious at the time of the offense and did not remember the events.
Procedural Posture:
- Willis Tony Caddell was prosecuted by the State of North Carolina in the Superior Court of Guilford County, a state trial court, on the charge of kidnapping.
- At trial, Caddell raised the defenses of insanity and unconsciousness.
- A jury convicted Caddell of kidnapping.
- Caddell appealed the judgment to the Supreme Court of North Carolina, the state's highest court.
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Issue:
Is the defense of unconsciousness, or automatism, an affirmative defense for which the defendant bears the burden of proof?
Opinions:
Majority - Lake, Justice
Yes. Unconsciousness is an affirmative defense, and the burden rests upon the defendant to establish it to the satisfaction of the jury. Overruling its prior decision in State v. Mercer, the court held that like insanity and intoxication, unconsciousness is an independent, substantive matter of exemption that the defendant must prove. The law presumes a person is conscious, just as it presumes sanity, and it is the defendant's burden to rebut that presumption. The court also held that evidence of the attempted rape was admissible because it was part of the same continuous transaction as the kidnapping and was relevant to show the purpose of the abduction.
Concurring-in-part-and-dissenting-in-part - Sharp, Chief Justice
No. Unconsciousness is not an affirmative defense because it negates the essential element of a voluntary act, which the State always has the burden to prove beyond a reasonable doubt. While concurring in the result to affirm the conviction, this opinion argues the majority needlessly overruled State v. Mercer. The plea of unconsciousness is analogous to alibi or accident; it is a denial of the State's case, not a plea of confession and avoidance. Proof that a defendant acted willfully and intentionally, which is the State's burden, necessarily disproves unconsciousness.
Analysis:
This decision significantly alters criminal defense strategy in North Carolina by classifying unconsciousness as an affirmative defense, thereby shifting the burden of proof from the State to the defendant. By overruling State v. Mercer, the court made it substantially more difficult for defendants to succeed with a defense of automatism or 'blackout.' The ruling aligns the procedural treatment of unconsciousness with that of insanity, requiring the defendant to affirmatively prove the condition to the jury's satisfaction, rather than simply raising a reasonable doubt about the voluntariness of their actions.
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