State of West Virginia, Plaintiff Below, Appellee v. Charles Rhea Hinkle, Defendant Below, Appellant

Summary

The West Virginia Supreme Court reversed Hinkle's involuntary manslaughter conviction for a faulty jury charge. The court held that unconsciousness (automatism) is a separate defense from insanity that negates the voluntariness of the act, and once raised by the defense the State must prove voluntariness beyond a reasonable doubt. Because the instruction given used civil negligence ('knew or should reasonably have known') rather than requiring actual knowledge combined with reckless disregard, and because no evidence supported a 'should have known' theory, the conviction was reversed and remanded for a new trial.