Can You Commit Murder in Your Sleep? The Unusual Defense Used in Some Violent Crime Cases

Many have attempted to use sleepwalking as a defense in harrowing cases over the years.

In the early hours of Sept. 1, 2017, Matthew Phelps called 911 to report that he may have stabbed his wife while dreaming.

The 29-year-old from Raleigh, N.C., said he awoke to find his wife, 29-year-old Lauren Hugelmaier Phelps, dead.

He told the operator that he’d gone to sleep after taking Coricidin cough & cold medicine and recalled having a dream. When he woke, he found his wife fatally stabbed on the floor of their bedroom, he told authorities.

“I have blood all over me and there’s a bloody knife on the bed and I think I did it,” Phelps says in the 911 call, which was released by authorities. “I can’t believe this.”

An autopsy revealed Lauren had 123 stab wounds, including 44 around her face and neck.

Phelps, an aspiring pastor who’d been married less than a year, has since been charged with first-degree murder. He’s pleaded not guilty.

Following Lauren’s death, the Bayer Corporation, which manufactures Coricidin, said, “There is no evidence that Coricidin is associated with violent behavior.”

The medication, however, does list nightmares and severe hallucinations on its list of rare side effects.

Phelps is just one of several people to have claimed that they committed crimes, including extremely violent ones, while sleeping.

Dr. Allen Towfigh, a neurologist and the director of New York Oncology and Sleep Medicine, said disorders may allow people to participate in complex behaviors while sleeping.

“Fortunately I have not had any patients who committed homicide, but I have certainly had patients who under various circumstances have engaged in violent behavior [in their sleep],” Towfigh told “One of my patients, who had a black belt in martial arts, broke down his entire dresser cabinet.”

Towfigh explained that a person’s stage of sleep can alter how much they might remember about what they did while asleep. But when drugs are introduced, things can get even more complicated, he said.

Numerous attorneys have used the “Ambien defense” in cases that range from DUI to murder. Ambien is a drug used to treat insomnia.

Charlie Saine, also of North Carolina, was accused of assaulting his wife and shooting at police after having three to four drinks and taking Ambien in January 2014. He was initially charged with four counts of assault with a deadly weapon but was acquitted in March 2016 after using the “Ambien defense.”

“Patients will take the medicine and have either alcohol before or afterwards and engage in these complex behaviors,” Towfigh said. “So it does happen and it’s believed to cause somewhat of a disconnected or dissociative state where you’re somewhat awake in some areas but asleep in others. It allows you to enter this skewed state.”

The defense doesn’t always work, however. That same year, a Philadelphia nun, 41-year-old Kimberly Miller, claimed she was “sleep driving” after drinking “altar wine” and taking Ambien. She claimed she had no recollection of ever getting into her car.

Nonetheless, she was later convicted of drunken driving.

Towfigh added that as a defense, he believes Ambien is becoming less justifiable.

“It’s so well known to cause this that patients should know better and shouldn’t be taking Ambien and drinking in combination,” he said.

In a statement to, Sanofi, the pharmaceutical company behind Ambien, said its priority is the safety of patients who take it.

"It’s always important for patients to read the medication guides for any medicines they are prescribed whether it’s the brand name product or a generic as the profiles of each medicine can be different." the Sanofi statement read. "Specifically, for Ambien, it is important that patients only take Ambien and Ambien CR as directed by their physician.

"The label clearly states Ambien should only be taken immediately before bed and only when you can get a full night’s sleep (7-8 hours). The medication guide also states not to take Ambien if you drank alcohol that evening or before bed."

It is not clear whether Phelps had any other drugs or alcohol in his system at time of his wife’s murder. 

Phelps’ attorney, Joseph Blount Cheshire, has asked that the public withhold judgment on the case until more developments are made.

“There’s a lot to this story, I believe, that will be told in the future,” Cheshire said in a previous statement. “Matthew’s family and all of us at my firm really send our deep condolences to the family of the young lady who died and to her family. It’s a very tragic situation, sad and tragic for both families.”

Cheshire did not respond to multiple requests for comment from

In cases where medicines were not involved, some juries have agreed that defendants were asleep at the time of their crimes.

In 2006, Ken Parks was acquitted of the 1987 murder of his mother-in-law and the attempted murder of his father-in-law after his attorneys argued he was asleep.  

Parks, then 23, reportedly drove 15 miles while sleeping to the Canada home of his in-laws, Barbara and Denis Woods. He reportedly fetched a tire iron from his trunk and then used a key to get into the house.

He entered the couple’s bedroom, where he choked his father-in-law until he was unconscious, authorities said. He then beat his mother-in-law with the tire iron before repeatedly stabbing her. He also stabbed his father-in-law.

At some point while he was in the home, Parks reportedly picked up the phone in the kitchen and set it down again so that it was off the hook. He also ran to the bedroom of his sister-in-law — a teenager at the time — and stopped outside her door before running from the home, according to reports.

Lawyers for Parks said that when he later regained consciousness he had blood dripping from his hands, which were severely cut, and immediately drove to a nearby police station at 4:45 a.m., telling cops, “My God, I’ve just killed two people… It’s all my fault,” the Los Angeles Times reported.

His mother-in-law passed away from her injuries, but his father-in-law survived.

Parks said he didn’t remember the details of the attack and police said he seemed oblivious to the severed tendons in his hands when he showed up at the station, according to reports.

At the time of the attacks, he was reportedly under major stress after being fired from his job. Two months before killing his mother-in-law, his then-employer, Revere Electric, found out that he’d allegedly stolen more than $30,000 from the company and had gambled the money away. He was waiting to appear in court on fraud charges at the time of the attacks.

Parks, who was also reportedly suffering from severe anxiety and insomnia before the attacks, underwent a series of sleep and psychological tests after the murder. 

Although prosecutors called the defense “simply ludicrous,” Parks was found not guilty in a decision that was later upheld by the Supreme Court.

In another 2015 case, Joseph Mitchell suffocated his 4-year-old son and attacked his two older children in his home in September 2010, but claimed he had been asleep at the time.

Devon Mitchell, then 10, and Alexis Mitchell, who was 13, told investigators they awoke to find their father trying to cover their mouths or faces and had to fend him off, according to court statements.

Alexis said she remembered someone pressing her head into her mattress and possibly blacked out, only to be awakened by her brothers' cries, WRAL reported.

Mitchell’s attorneys said Mitchell simply walked away when his daughter elbowed and bit him. 

Mitchell then reportedly locked himself in his home office. When authorities arrived after the children’s grandfather called 911, Mitchell had self-inflicted cuts to his torso and neck.   

Mitchell’s attorneys called health experts to testify that he was suffering from stress and lack of sleep before the alleged crimes, causing him to have no recollection of the attacks, ABC News reported.

He was found not guilty of first-degree murder and two counts of attempted murder in 2015. 

Towfigh said crimes such as these can occur in the context of a perpetrator’s dream.

“In REM disorder there is common content of either an intruder breaking into the house or some threat to either the individual or the family and they will react to that perceived threat,” Towfigh said. “Anyone who is unfortunate enough to be in the bedroom or close by can become a victim of whatever dream plot that individual is experiencing.”

While Towfigh said it is possible for this to happen, the defense hasn’t always held up in court. 

Stephen Reitz went on trial after he killed his girlfriend, 42-year-old Eva Marie Weinfurtner, while on vacation in October 2001. Reitz, then 42, threw a flower pot at Weinfurtner’s head, which cracked her skull, and he then beat her repeatedly before stabbing her in the neck, according to reports.

He claimed he woke up and found her body at the foot of the bed after dreaming that he was fighting off an intruder. Reitz also told authorities the two had been drinking and using cocaine before the murder.

The defense argued Reitz had a history of mental problems and was capable of being violent while asleep, but the jury didn’t buy it. Weinfurtner’s family reportedly noticed bruises on her body in the months leading up to the slaying and encouraged her to leave him. 

Several jurors said the panel might have been convinced by a sleepwalking defense if Reitz had just thrown the flower pot, “but the attack that followed convinced them that his defense was implausible,” the LA Times previously reported.

Reitz was found guilty of first-degree murder.

In Phelps’ case, the details are still murky, but he could face the death penalty if convicted of killing his wife. 

Towfigh, however, said there are precautions individuals can take to help prevent irregular sleep behaviors.

“Try not to mix hypnotics and sleep aids with alcohol. Make sure you are going to bed if you are taking a sleep aid,” Towfigh said. “If you know yourself to have this tendency of having these kind of dissociative or disconnected states where you either sleep walk or sleep eat  then you should make your medical provider aware of that and take additional precautions to reduce the likelihood of having some [unfortunate] event like this occur.”