The night before May 24, 1987, young Kenneth Parks went to sleep like a normal man, but woke up the next day as a brutal killer. What followed was a landmark case of defense that nobody had seen in legal history.
Parks was a seemingly normal 23-year-old living in Pickering, Ontario, having a loving relationship with his wife, Karen Woods, and in-laws, Barbara Ann and Dennis Woods. However, in the early morning hours of May 24, 1987, he drove 14 miles to Scarborough and brutally killed his sleeping in-laws with a tire iron and a knife. Right after, he drove straight to a police station and confessed, “I think I killed someone.”
The shocking part came when Parks appeared confused and unaware of his crime as well as his own injuries. At the trial held in 1988, it was established by five neurological experts that he was sleepwalking and had no conscious memory of killing his in-laws. He was determined to be suffering from a sleep disorder by the doctors, rather than a neurological, psychiatric, or other illness.
Parks’ defense of sleepwalking
Parks’ legal team then presented a defense of automatism, arguing that an individual cannot be held criminally responsible for an act committed involuntarily. His defense was also supported by a lack of motive and a brain wave survey that proved he naturally cycles through sleep phases more frequently than most people. Parks also experienced no physical pain during the attack, despite tearing several tendons that required surgery, and awoke only when he reached the police station.
However, the prosecution called it ridiculous and questioned how Parks could perform “a series of complex actions,” including driving 14 miles, locating his in-laws’ house, and carrying out a brutal attack, all while unconscious. But all evidence suggested that Parks was actually sleepwalking, and the jury decided to acquit him of the crime after nine hours of deliberation.
The Supreme Court case: Her Majesty The Queen v Kenneth James Parks
The prosecution appealed the case in the Supreme Court of Canada. The court was asked to decide whether sleepwalking qualifies as non-insane automatism or if it should be categorized as a “disease of the mind” (i.e., mental disorder automatism) and result in a not guilty conviction for insanity.
Following the hearing, Chief Justice Antonio Lamer held that the trial judge was right to analyze the evidence and refrain from classifying sleepwalking as a mental condition. Parks was completely acquitted of the first-degree and second-degree murder charges after the ruling upheld that sleepwalking may be regarded as a type of non-insane automatism.
The court noted Parks’ case was of a sleep disorder, not a psychiatric illness, and that the likelihood of recurrence was low, establishing an important legal precedent.
