R v Quick

R v Quick [1973] QB 910 is an English criminal case, as to sane automatism and the sub-category of self-inducement of such a state. The court ruled that it may not be used as a defence if the defendant's loss of self-control was on the part of negligence in consuming or not consuming something which someone ought to but the jury must be properly directed so as to make all relevant findings of fact. The ruling stresses that automatism is usually easily distinct from insanity, in the few cases where the lines are blurred it is a complex problem for prosecutors and mental health professionals.

William G.H. Quick was a nurse in a mental hospital, charged with assaulting a patient. He claimed that he had been acting involuntarily as a result of common hypoglycaemia of diabetics, induced by an over-generous insulin and he had not neutralised its effects with food, which made him violently aggressive. The trial judge ruled that this constituted insanity, not automatism. Rather than risk the stigma of an acquittal on such grounds and a likely imposed treatment plan with loss of employment, the defendant changed his plea to guilty, got a conviction, and then appealed arguing he was not negligent in reaching a state of automatism whilst in a position of responsibility. The court noted alike incidences often are appealed to seek to re-argue non-negligence and thus evade criminal liability. At appeal it was ruled that the trial judge was mistaken, and that diabetic hypoglycaemia was induced by an external factor, and therefore gave rise to automatism, not insanity. The indicted facts should never had been reinterpreted as indicating insanity.