People v. Grant
Appellate Court of Illinois, Fourth District
360 N.E.2d 809 (1977)
While intoxicated at a tavern, Grant (defendant), who had a history of violent behavior, struck a police officer arresting another patron and was later subdued, jailed, and suffered an apparent grand mal seizure in his cell; at trial for aggravated battery and obstructing an officer, a doctor testified Grant was likely suffering a psychomotor seizure from underlying epilepsy at the time of the attack, rendering his conscious mind unable to control his behavior. The trial judge instructed the jury on insanity but not on involuntary conduct, and Grant was convicted on both charges and appealed.
Whether a criminal defendant is entitled to a jury instruction on the defense of involuntary conduct or automatism, distinct from insanity, where evidence suggests an underlying medical condition rendered him unconscious of his actions during the offense.