"Not conscious, not responsible, not guilty."
The story of Kenneth Parks is one of the most bizarre criminal cases in Canadian history. It also set a precedent in Canadian law about criminal defense as it was ultimately decided by the Supreme Court of Canada.
The Death of Barbara Woods
On May 24th, 1987, Kenneth Parks got up from his bed, got in his car, and drove 20 miles from Pickering, Ontario, to his in-laws' house in Scarborough, Ontario. Then, Parks proceeded to enter his in-law's house with a key they had previously given him. After entering, he encountered his mother-in-law, Barbara Woods, and struck her with a tire iron. After Barbara fell to the floor, Parks took a knife and stabbed Barbara four times, killing her instantly. Then, he turned to his father-in-law, Denis Woods, and had a failed attempt to strangle him to death. After believing he had killed both people, Parks returned to his car and drove to a police station. Parks then turned himself over to the police covered in blood, stating, "I think I have just killed two people." Parks was charged with one count of murder and another count of attempted murder.
The Trial of Kenneth Parks
The trial of Kenneth Parks was significant in the Canadian legal system because the unique defense, led by Marlys Edwardh, said that on the night of the killing, Parks ″plunged into a deep, deep sleep. His next memory is seeing his mother-in-law's face.″ This was one of the first times in Canadian history that sleepwalking was used as a defense in a trial. Ergo, there were few laws to decide its outcome, and the verdict would greatly rely on the jury and whether they would accept such an argument. The defense intended to use expert testimony and witnesses of Park's behavior to build a case that could reasonably argue this unique approach to a murder trial. They heavily relied on Staff Sgt. Bob Adair of the Toronto police homicide squad as he testified that he had no idea how he got to his in-laws' home and told officers he had no reason to harm them. They paired this testimony with views from five neurological experts who conclusively confirmed that Park was in a sleepwalking state during the time of the incident. The prosecution wished to find evidence to show that Park's had a motive to murder the Woods, but they failed to provide evidence that proved guilt beyond a reasonable doubt.In closing statements, Edwardh stated that Parks had shown a history of sleepwalking and asked the jury to vote for acquittal because he was in ″a sleep-state in which ... there is no will or conscious mind directing [the activity].″ After nine hours of deliberation, the jury agreed with the defense's argument and acquitted Kenneth Parks of all crimes. But this case brought up an issue before the Supreme Court. They had to decide whether the condition of sleepwalking could be classified as non-insane automatism or whether it should be classified as a "disease of the mind" and warrant a verdict of "not guilty for reason of insanity." This distinction was sent to the desk of Chief Justice Antonio Lamer. He ruled that the trial judge was correct in his decision not to characterize sleepwalking as a mental disorder.