considered, such as any unexpected heart attacks or epileptic seizures. However, she believes that the better analysis of someone who is unable to control their motor vehicle because of the onset of some disease (or something beyond their control) should be that the actus reus element is not established. She argues that the onset of the disease and the subsequent erratic driving amounts to an involuntary act. The actus reus of the offence cannot be established unless the act is voluntary. Thus we need not reach the question of what a reasonable person would have been thinking or adverting to as the car goes off the road, much less what the accused was in fact thinking or not thinking. See also R v DeSousa R v Tutton References External links Supreme Court of Canada cases 1993 in Canadian case law Canadian criminal case law