R v Quick
Automatism caused by an external factor, such as an injection of insulin, is non insane automatism, which leads to a complete acquittal.
Facts
Mr Quick, a nurse at a psychiatric hospital, was a diabetic. He assaulted a patient. He said that he had taken insulin that morning and had not eaten enough, so that he was suffering from hypoglycaemia, low blood sugar, and did not know what he was doing. The judge ruled that this was evidence of insanity, not automatism, so Mr Quick pleaded guilty, and then appealed.
Legal principle
The Court of Appeal quashed the conviction. Lawton LJ said that Mr Quick's condition was caused by an external factor, the insulin he had injected, not by the diabetes itself, so it was not a disease of the mind. He was entitled to rely on the defence of non insane automatism, which, if successful, would lead to a complete acquittal. The court said that a malfunctioning of the mind of transitory effect caused by the application to the body of some external factor, such as violence, drugs, including anaesthetics, alcohol and hypnotic influences, cannot fairly be said to be due to disease.
Related cases on defences: insanity, automatism and intoxication
- Attorney General for Northern Ireland v Gallagher [1963] AC 349
- Attorney General's Reference (No 2 of 1992) [1994] QB 91
- DPP v Majewski [1977] AC 443
- Hill v Baxter [1958] 1 QB 277
- M'Naghten's Case (1843) 10 Cl & F 200
- R v Bailey [1983] 1 WLR 760
- R v Burgess [1991] 2 QB 92
- R v Coley; R v McGhee; R v Harris [2013] EWCA Crim 223
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This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
