## Facts

- A 14-year-old girl was seized from her home driveway in Guilford County, forced into an automobile, and driven to a wooded area in neighboring Randolph County.
- In the wooded area, the assailant beat her with a tool and attempted to rape her before fleeing.
- The abduction, transport, and assault occurred within roughly 20 minutes and within about three miles.
- The State introduced photographs of the car and physical evidence including a bloody chisel and the victim’s clothing, along with fingerprint and palm-print evidence linking the defendant to the vehicle and chisel.
- The State also introduced evidence of the defendant’s flight from North Carolina and later arrests outside the state.
- The defendant testified he had no memory of the events and offered psychiatric evidence describing a sociopathic, antisocial condition with extreme aggressiveness.
- The defendant pleaded not guilty and relied on insanity and unconsciousness (automatism) as defenses.
- A Guilford County jury convicted the defendant of kidnapping, and the trial court imposed a life sentence.

## Issues

1. Whether evidence of the beating and attempted rape in Randolph County was admissible in a Guilford County prosecution for kidnapping.
2. Whether the trial court properly admitted challenged evidence, including photographs, the chisel, clothing, fingerprint evidence, and certain statements and exclamations.
3. Whether unconsciousness (automatism) is a recognized defense and, if so, whether it is an affirmative defense with the burden on the defendant.
4. Whether the jury instructions on the burdens of proof for insanity and unconsciousness were erroneous and, if erroneous, whether the error required a new trial.
5. Whether evidence of flight was properly admitted and how it could be used by the jury.

## Decision

- The Supreme Court of North Carolina affirmed the kidnapping conviction and life sentence.
- The court held that evidence of the beating and attempted rape was admissible because the acts were part of a single continuous transaction and explained the purpose and context of the kidnapping.
- The court upheld admission of the challenged physical and testimonial evidence, including illustrative photographs and corroborative testimony, and rejected hearsay objections where statements were admitted to show circumstances and condition rather than truth.
- The court treated unconsciousness as a complete defense but an affirmative defense that the defendant must prove to the satisfaction of the jury.
- The court reaffirmed insanity as an affirmative defense that the defendant must prove to the satisfaction of the jury under the stated test for criminal responsibility.
- Although the trial court misstated the burden on unconsciousness by instructing that the defendant was not required to prove it, the error favored the defendant and was not prejudicial.
- The court approved the admission of flight evidence as circumstantial evidence of consciousness of guilt, while noting it is not sufficient by itself to establish guilt.

## Legal Principles

- Evidence of other criminal acts may be admitted when the acts are so connected in time and circumstance with the charged offense that the State cannot fully present the charged offense without showing the entire transaction.
- Relevant photographs and physical items may be admitted to illustrate testimony and depict the crime scene, injuries, and connected circumstances.
- Out-of-court utterances may be admissible when offered to show surrounding circumstances, the victim’s condition, or the event’s occurrence, rather than to prove the truth of the words asserted.
- Prior consistent statements may be admitted for corroboration despite minor discrepancies, so long as they are generally consistent with in-court testimony.
- Unconsciousness (automatism) is a recognized, complete defense in North Carolina, but it is an affirmative defense the defendant must establish to the satisfaction of the jury.
- Insanity is an affirmative defense; the defendant must prove to the satisfaction of the jury that, due to mental disease or defect, the defendant did not know the nature and quality of the act or did not know the act was wrong.
- Evidence of flight may be considered with other circumstances as tending to show consciousness of guilt, but it is not alone sufficient to prove guilt.

## Conclusion

The court affirmed the kidnapping conviction, permitting detailed proof of the related assault as part of the same continuous transaction and clarifying that unconsciousness, like insanity, is a complete but affirmative defense that the defendant must prove to the satisfaction of the jury; an instructional error reducing that burden did not warrant reversal.


State v. Caddell, 287 N.C. 266, 215 S.E.2d 348 (N.C. 1975)