The date is January 16, 1997. Scott Falater is a successful businessman, married to his high school sweet heart, and the father of two teenage children. Life is great for him and his family. However, he has been under a lot of stress at work and not sleeping well. At dinner, he talks about his job and the certain aspects of it that are causing him so much stress. Afterwards, his wife asks him to see what is wrong with the filter for the pool in the backyard. He works on this till dark, kisses his wife goodnight, and heads to bed sometime between 9:30 and 10:00pm. At about 10:30pm, the next-door neighbor wakes up to the sound of a woman screaming. He goes to his window, and sees a bloodied woman beside the pool. He then sees Scott Falater come outside, stare blankly over the dead body of his wife, roll her into the pool, and then walk back inside. Sounds like Scott Falater murdered his wife, right? Well, Scott has no memory of this. In court, his defense was based on the premise that he was sleepwalking. Is this a legitimate legal defense? Was he convicted?
First, let’s go through some basics of sleepwalking. Sleepwalking belongs to the family of parasomnia sleep disorders, and is characterized by a series of complex behaviors that are initiated during deep sleep. This does not happen during REM sleep, the stage in which we dream, and usually occurs during the first third of the night. Something mysterious happens with sleepwalkers, in that they are able to navigate their environment, but do not seem able to recognize the faces they come across. This is because the pathways in our brain responsible for visually guided movement and facial recognition are in different areas of the brain. So, the part of the brain responsible for facial recognition appears to be “asleep” in sleepwalkers, while the area that runs visually guided movements is not.
Sleepwalking can also turn aggressive. Sleep-related aggression has an estimated prevalence rate of 2.1%, and occurs mostly in men. This particular case is an extreme example; sleep-related aggression rarely turns into murder. It is most often choking, punching, etc. But how does someone go from passive sleepwalking into an aggressor? This is not yet known. One theory was that those who are aggressive sleepwalkers have an underlying psychopathology, but research has not shown any relationships between the two.
Now let me give you the rest of the story. After Scott fell asleep, he slept walk outside and continued working on the pool filter. When his wife noticed he was out working on it again, she went out to tell him to call it a night. However, she probably did not realize that he was sleepwalking. This startled him-often called a confusion arousal- and this then progressed into him murdering his wife. He then went into the garage to put his tools in their appropriate place, and then went back outside. This is when the neighbor watched Scott roll his wife into the pool and go back inside. Scott went back to bed, and was eventually wakened by noises coming from the first floor of his house. He went downstairs, and was immediately arrested.
Scott did not have any prior intent, did not appear to be conscious at the time of the crime, and did not present any psychological disorders. Do you think he should be responsible for the crime? This is important to consider. In our criminal justice system, defendants who are deemed mentally ill are not held to the same legal standards.
Should sleepwalkers be treated the same way? In the case of Scott Falater, he was sentenced to life in prison. However, there are a number of other similar cases in which the defendant was found not guilty. When someone is accused of a violent crime and they claim they were sleepwalking, they go through a large battery of evaluations to test the legitimacy of their defense. Much more development and research is needed to refine the development of sleep-related aggression and its treatment.
Please feel free to share your thoughts on this in the comments. Also, if you would like to learn more about this case (or similar ones) please feel free to contact us.
Cartwright, R. (2004, July). Sleepwalking violence: A sleep disorder, a legal dilemma, and a psychological challenge. Psychiatry, 161(7), 1149-1158.