State v. Caddell Case Brief Summary | Law Case Explained

State v. Caddell | 215 S.E.2d 348 (1975)

In most jurisdictions, a criminal defendant has the burden of proving the affirmative defense of insanity. But what about a defendant who claims he was unconscious? Is unconsciousness treated like the insanity defense? The North Carolina Supreme Court took up that question in State versus Caddell.

14-year-old Catherine Sutton was standing in her driveway when Willis Caddell physically forced her into his car. Caddell then drove to a wooded area where he choked Sutton, repeatedly beat her over the head, and tried to rape her. When Sutton played dead, Caddell dragged her out of his car and ran away.

The State of North Carolina charged Caddell with kidnapping. At trial, Caddell claimed he was unconscious during the incident. The judge instructed the jury that because unconsciousness is not an affirmative defense, the defendant doesn’t have the burden to prove he was unconscious. The judge also instructed the jury to find Caddell not guilty if they found that he was unconscious during the incident.

The jury convicted Caddell, and he appealed to the North Carolina Supreme Court.

On appeal, Caddell argued that by instructing the jury to find him not guilty if he was unconscious, the judge erroneously placed the burden of proof on him. Instead, Caddell contended, the judge should’ve instructed the jury to find him not guilty unless the state proved beyond a reasonable doubt that he was conscious.

Did we just become best friends? Stay connected to Quimbee here:

#casebriefs #lawcases #casesummaries

[Zghost]

Tell me how someone can drive a car while unconscious?