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State v. Hinkle - 200 W. Va. 280, 489 S.E.2d 257 (1996)

Rule:

A refusal to give a requested instruction is reviewed for an abuse of discretion. When assessing whether the trial court properly exercised that discretion, a reviewing court must examine the instructions as a whole to determine if they sufficiently cover the issues in the case and focus on the facts presented by the evidence.

Facts:

Defendant Charles Rhea Hinkle sought review of a decision by a West Virginia trial court, which rendered judgment on a jury verdict convicting Hinkle of involuntary manslaughter, and subsequently denied Hinkle's motions for a judgment of acquittal and a new trial. At Hinkle's trial on the charge of involuntary manslaughter, the evidence showed that he suffered from an undiagnosed brain disorder which had rendered him unconscious, thus causing the fatal accident. Hinkle's requested jury instruction on the insanity defense was denied, and the jury was instructed on the unconsciousness defense. Hinkle appealed, contending that the lower court erred in denying his insanity instruction. The State contended that the evidence did not support an insanity instruction, and that the unconsciousness instruction was adequate. 

Issue:

Was the jury instructed properly as to the defense of unconsciousness?

Answer:

No.

Conclusion:

The state supreme court reversed the trial court's judgment and remanded the case for a new trial. The court ruled that although the insanity defense did not apply, the instructions on the unconsciousness defense were inadequate. The court found that: (1) unconsciousness was a separate defense from insanity, which eliminated the voluntariness of the act, while insanity negated the actor's mental state; (2) the unconsciousness instruction should have focused more on gross negligence rather than simple negligence in that it should have made clear that Hinkle knew of his condition, and knew it could impair his driving ability; and (3) there was no evidence that Hinkle "should have known" of his brain disorder.

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