State v. Fields

Supreme Court of North Carolina
324 N.C. 204, 1989 N.C. LEXIS 94, 376 S.E.2d 740 (1989)

ELI5:

Rule of Law:

A defendant is entitled to a jury instruction on the defense of unconsciousness or automatism when they present legally sufficient evidence, such as expert testimony, that they were unable to exercise conscious control over their actions at the time of the offense.

Facts:

When he was fourteen years old, the defendant, Wayne Fields, shot and killed his abusive stepfather, 'Dump,' while Dump was threatening Fields' mother with a knife.
Following this traumatic event, Fields suffered from nightmares, developed a protective attitude toward his female family members, and was described as acting as if he were 'in his own world.'
Years later, Fields’ half-sister, Connie Williams, was in an abusive relationship with Isaiah Barnes, the victim.
On September 18, 1986, Fields was at a house with Williams and Barnes.
According to Fields' account to his psychologist, he saw Barnes grab Williams' bandaged arm, causing her to grimace in pain.
This act allegedly triggered a disassociative state in Fields, causing him to have flashbacks of his stepfather's abuse.
Fields then pulled out a gun and shot Barnes twice, killing him.

Procedural Posture:

Wayne Fields was prosecuted for first degree murder in a North Carolina trial court.
At trial, the defense presented evidence to support a defense of unconsciousness and requested a corresponding jury instruction.
The trial court refused to give the jury instruction on unconsciousness.
The jury convicted Fields of first degree murder.
The trial court sentenced Fields to life imprisonment.
Fields appealed his conviction to the Supreme Court of North Carolina, arguing the trial court erred by refusing the requested instruction.

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Issue:

Does a trial court err by refusing to provide a jury instruction on the defense of unconsciousness when the defendant presents expert psychological testimony, corroborated by family members, that he was in a disassociative state and acting like an 'automaton' at the time of the killing?

Opinions:

Majority - Whichard, Justice

Yes. A trial court errs by refusing to instruct the jury on the defense of unconsciousness when the defendant presents sufficient evidence to support that defense. The defense of unconsciousness, or automatism, is a complete defense to a criminal charge because the absence of consciousness precludes the possibility of a voluntary act, which is a prerequisite for criminal liability. In this case, Fields presented legally sufficient evidence through the testimony of his family about his traumatic history and the expert opinion of a clinical psychologist, Dr. Harrell. Dr. Harrell testified that Fields suffered from post-traumatic stress disorder and was in a disassociative state when he shot Barnes, rendering him unable to 'exercise conscious control of his physical actions' and causing him to act 'like a robot' or 'an automaton.' This evidence, if believed, would establish the defense. The weight and credibility of such evidence are for the jury to determine, not the trial judge, and therefore Fields was entitled to the requested instruction.

Analysis:

This case solidifies the defense of automatism (unconsciousness) as a complete, affirmative defense distinct from insanity in North Carolina. The ruling emphasizes that the trial judge's role is not to weigh the credibility of the evidence supporting a defense, but merely to determine if it is legally sufficient to be presented to the jury. The decision gives significant weight to expert psychological testimony, particularly concerning conditions like PTSD, in establishing a defendant's mental state. It provides a crucial legal pathway for defendants whose criminal actions may stem from severe past trauma, allowing them to argue that their conduct was not the product of a conscious, voluntary choice.

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