State v. Utter
Court of Appeals of Washington
479 P.2d 946 (1971)
Relevant factsFree
Utter (defendant), who had been drinking heavily, fatally stabbed his son, who staggered out of Utter's apartment saying his father had stabbed him; Utter had no memory of the event. At trial, Utter argued the stabbing was an automatic "conditioned response" from his wartime training to react violently to sudden approach, but the trial court equated this to the unrecognized defense of irresistible impulse and instructed the jury to disregard the evidence. The jury convicted Utter of manslaughter, and he appealed.
IssueFree
Whether a defendant's act occurring during an unconscious or automatistic state can serve as a basis for criminal liability.