Law School Case Brief
People v. Humphrey - 13 Cal. 4th 1073, 56 Cal. Rptr. 2d 142, 921 P.2d 1 (1996)
Although the belief in the need to defend must be objectively reasonable, a jury must consider what would appear to be necessary to a reasonable person in a similar situation and with similar knowledge. It judges reasonableness from the point of view of a reasonable person in the position of defendant. To do this, it must consider all the facts and circumstances in determining whether the defendant acted in a manner in which a reasonable man would act in protecting his own life or bodily safety. A defendant is entitled to have a jury take into consideration all the elements in the case which might be expected to operate on his mind.
Defendant shot and killed the man with whom she had been living. She testified that the man had frequently beaten her and threatened to kill her, and that she shot him in self-defense. Defendant’s testimony regarding the man’s abusive conduct and threats was corroborated, as was her testimony that the victim shot at her the night before the fatal shooting. In addition, an expert witness testified that defendant suffered from an extreme pattern of battered women’s syndrome. The trial court instructed the jury that it could consider the evidence regarding battered women’s syndrome in deciding whether defendant actually believed it was necessary to kill in self-defense, but not in deciding whether that belief was reasonable. Consequently, the jury convicted defendant of voluntary manslaughter with personal use of a firearm. The Court of Appeals affirmed the judgment. Defendant appealed.
Was the trial court’s instruction regarding the battered women syndrome erroneous?
The Court held that the trial court erred when it instructed the jury not to consider the battered women's syndrome evidence in deciding whether defendant's belief in her need to defend was reasonable. Evidence of battered women's syndrome is generally relevant to the reasonableness, as well as the subjective existence, of a defendant's belief in the need to defend, and, to the extent it is relevant, the jury may consider it in deciding both questions. The proffered evidence was also relevant to defendant's credibility, since it would have assisted the jury in objectively analyzing defendant's claim of self-defense by dispelling the commonly held misconception that a battered woman was free to leave at any time and would have left if the beatings were really that bad. The court also held that the trial court's error was prejudicial, since the jury found defendant guilty of voluntary manslaughter, not murder, and the jury's request for clarification of the terms "subjectively honest" and "objectively unreasonable" suggested the question of unreasonable self-defense was critical.
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