State v. ColemanÂ, 254 N.C. App. 497

Background

On April 22, 2013, Matthew Coleman shot and killed his wife; he admitted the shooting but claimed automatism (unconsciousness) caused by hypoglycemia due to Type I diabetes.
Neighbors discovered Coleman shortly after the shooting; he told them he had killed his wife, then discarded the gun and was found with three briefcases containing large amounts of cash and documents.
Coleman was indicted for first-degree murder; he pleaded not guilty and asserted an automatism defense based on low blood sugar. Trial evidence included glucometer logs and medical history of hypoglycemic episodes.
Defense expert Dr. George Corvin testified Coleman acted in automatism from hypoglycemia; the State’s expert endocrinologist Dr. Warner Burch testified automatism was unlikely.
Jury convicted Coleman of the lesser-included offense of voluntary manslaughter; he was sentenced to 64–89 months and appealed, arguing insufficiency of evidence and several evidentiary and instructional errors.

Issues

Issue	State's Argument	Coleman’s Argument	Held
Denial of directed verdict on voluntary manslaughter	State presented sufficient evidence that Coleman intentionally shot and killed his wife; automatism disputed by State expert.	Court should have dismissed because State failed to prove essential elements or voluntariness given automatism defense.	Denial affirmed: sufficient evidence for voluntary manslaughter (intentional unlawful act and proximate cause); jury could reject automatism.
Cross-examination of defense expert about fees	Questioning was relevant to possible bias/partiality of the expert.	Argued questioning about fees was irrelevant and inadmissible.	Admissible: evidence of fees is relevant to test for partiality; trial court did not err.
State expert testifying about defendant’s state of mind	Endocrinologist’s opinion about absence of automatism was within his expertise on hypoglycemia signs/symptoms.	Testimony improperly invaded jury’s role by opining on Coleman’s mental state.	Admissible: expert was qualified and applied reliable methods; court did not abuse discretion.
Jury instruction on automatism (burden and standard)	Pattern instruction correctly explained that defendant must prove automatism to jury’s satisfaction and State must prove other elements beyond a reasonable doubt.	Instruction allegedly implied defendant had to prove automatism beyond a reasonable doubt (plain error).	No error: instructions tracked pattern language, correctly allocated burdens and stated effect of a finding of automatism.
Omission of involuntary manslaughter instruction	No evidence supporting lack of intent to fire the weapon; involuntary manslaughter not supported.	Court should have submitted involuntary manslaughter as a lesser-included offense.	No plain error: no evidence suggested the shooting was accidental or lacked intent to discharge; omission proper.

Key Cases Cited

State v. Mize, 315 N.C. 285 (1985) (standard for denial of directed verdict/motion to dismiss)
State v. Fritsch, 351 N.C. 373 (1999) (substantial evidence review explained)
State v. Rose, 339 N.C. 172 (1994) (consideration of all evidence in dismissal review)
State v. McGrady, 368 N.C. 880 (2016) (expert testimony admissibility under Rule 702)
State v. Cummings, 352 N.C. 600 (2000) (cross-examination probing expert partiality/bias)
State v. Brown, 335 N.C. 477 (1994) (addressing rebuttal of bias inference about expert fees)
State v. Millsaps, 356 N.C. 556 (2002) (when lesser-included offense instructions are required)
State v. Robbins, 309 N.C. 771 (1983) (involuntary manslaughter requires absence of intent to discharge weapon)