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There can be no criminality in the absence of criminal intention and when the court ascertains from medical experts or otherwise that there is such a thing in nature as somnolentia and somnambulism, the task of the jurist is ended, so far as relates to the right of one accused of crime to offer evidence conducing to prove that he committed the act imputed to him as a crime while in a paroxysm of somnolentia or somnambulism. In criminal trials, the jury must try every pertinent question of fact the evidence conduces to prove. When evidence is offered, the sole question for the court is, will it conduce to prove any fact material in the case and if the law gives an affirmative response, the evidence must be admitted.
Defendant was asleep in a public place of a hotel. A porter at the hotel attempted to wake defendant up. He began to shake defendant and grasped defendant by the coat and attempted to lift him up. Defendant drew a pistol and fired three shots into the porter. The porter later died. At defendant's trial for murder the trial court refused to allow defendant to introduce evidence that defendant had been a sleepwalker since infancy and sometime would behave as if awake when defendant was really asleep. Defendant also offered testimony by medical experts that persons asleep sometimes act if they were awake. The trial court refused the offered medical testimony and defendant was convicted of manslaughter. Defendant appealed, arguing that the trial court improperly excluded evidence that defendant did not have criminal intent because defendant was asleep and suffered from somnambulism.
Did the trial court improperly exclude evidence of defendant's sleepwalking and somnambulism?
On appeal, the court reversed. It held that medical experts had recognized a species of mental unsoundness connected with sleep that was commonly treated under the general head of somnambulism. The court held that the trial court should have allowed the evidence of defendant's sleepwalking and somnambulism that was relevant to defendant's mental state. It remanded for a new trial.