Summary of People v. Newton, California District Court of Appeal (1970)

Defendant: Newton; the defendant shot and killed a police officer in an altercation. The defendant argued that he was shot in the abdominal area first by one of the officers and then he became unconscious and he does not remember shotting the officer. The trial court did not allow this unconscious defense and the defendant was found guilty of voluntary manslaughter by the jury.

Issue: Did the court make an error by not letting the defendant use his unconciousness as a defense?

Holding: Yes

Legal Reasoning: The court ruled that aside from voluntary drunkeness, unconsciousness can perfectly be used as a defense in homicide cases. The court considered the testimony of the doctor who told the court the after being shot on the abdominal area, many people become unconscious. So the court ruled that the trail court made an error by not letting the defendant introduced the evidence of his unconsciousness state when he shot the officer.