Smith's Criminal Case Compendium
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State v. Coleman, ___ N.C. App. ___, 803 S.E.2d 820 (Jul. 18, 2017)
In this homicide case, the trial court did not err by allowing the State’s expert witness on automatism to testify to the defendant’s state of mind at the time of the shooting. The expert endocrinologist testified that based on his experience with hypoglycemia and his review of the defendant’s medical records and account of what had occurred on the day of the shooting, the defendant’s actions were “not caused by automatism due to hypoglycemia.” The court rejected the defendant’s argument that this testimony, while couched in expert medical testimony, was merely speculation about the defendant state of mind at the time of the shooting. Here, the expert testified that in his opinion the defendant was not in a state of automatism at the time because he did not suffer from amnesia, a key characteristic of the condition. The trial court acted well within its discretion by admitting this testimony.