Grant (defendant) had been drinking alcohol at a tavern when the police were summoned to arrest another patron. Grant, who had a history of violent behavior, broke through a crowd that was watching police officers take the other patron to their car and struck one of the officers. Grant was subdued by another officer with the use of great force, placed in the police car, and taken to the county jail. While in his cell, Grant suffered what appeared to be a grand mal seizure. At his trial for aggravated battery and obstructing a police officer, Grant offered testimony by a doctor that at the time of the attack Grant was suffering from a psychomotor seizure, brought on by a form of epilepsy that had also caused the grand mal seizure. The doctor gave his opinion that in this state Grant’s conscious mind could not control his behavior. The trial judge instructed the jury on the issue of insanity but not on the defense of involuntary conduct. Grant appealed his conviction on both charges.