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State v. Sexton - 160 N.J. 93, 733 A.2d 1125 (1999)

Rule:

A sample jury instruction when a defendant asserts that he mistakenly believed the gun was not loaded is as follows: In this case, ladies and gentlemen of the jury, the defendant contends that he mistakenly believed that the gun was not loaded. If you find that the State has not proven beyond a reasonable doubt that the defendant was reckless in forming his belief that the gun was not loaded, defendant should be acquitted of the offense of manslaughter. On the other hand, if you find that the State has proven beyond a reasonable doubt that the defendant was reckless in forming the belief that the gun was not loaded, and consciously disregarded a substantial and unjustifiable risk that a killing would result from his conduct, then you should convict him of manslaughter. 

Facts:

Defendant Ronald Sexton was charged with and indicted for purposeful or knowing murder, possession of a handgun without a permit, and possession of a handgun for an unlawful purpose. He and the decedent, Matthews, had been engaged in what was described by a witness as a "typical argument," when Sexton pointed a gun at Matthews that Matthews had earlier handed him to examine. The gun belonged to Matthews' grandmother. When Sexton pointed the gun at Matthews, Matthews commented that the gun was not loaded. Sexton said to Matthews, "you think there are no bullets in this gun?" Matthews replied, "yeah," and the witness heard the gun fire. A single bullet killed Matthews. Sexton's version of the encounter was that the gun simply went off while he was examining it. Matthews, he said, had assured him that it was not loaded. At trial in New Jersey state court, Sexton's attorney moved to dismiss the murder charge because Matthews had told Sexton that the gun was not loaded. The trial court denied the motion and charged the jury on the charges of murder and the lesser-included offenses of aggravated manslaughter and reckless manslaughter. The jury found Sexton not guilty of murder, aggravated manslaughter, or possession of a handgun for an unlawful purpose, but guilty of reckless manslaughter and unlawful possession of a handgun without a permit. On appeal, the appellate division reversed Sexton's conviction for reckless manslaughter, finding that the trial judge erroneously charged the jury on first degree murder, despite the absence of any credible evidence that Sexton intended to kill or seriously injure Matthews and that the trial court should have charged the jury that the State bore the burden of disproving beyond a reasonable doubt Sexton's mistake-of-fact defense, and that the failure to do so was plain error. Although the appellate division reversed the conviction on several other grounds, the state supreme court granted the State's petition for certification, limiting the petition to the issue of whether mistake of fact was a defense to the charge of reckless manslaughter.

Issue:

Was mistake of fact a valid defense to the charge of reckless manslaughter?

Answer:

Yes.

Conclusion:

The Supreme Court of New Jersey affirmed the appellate division's judgment. The court held that a mistake of fact can be a defense to a charge of reckless manslaughter if the mistake was reasonable and it negated the culpable mental state required to establish the offense. The court explained that to require the State to disprove beyond a reasonable doubt a defendant's reasonable mistake of fact introduced an unnecessary and perhaps unhelpful degree of complexity into the fairly straightforward inquiry of whether defendant "consciously disregarded a substantial and unjustifiable risk" that death would result from his conduct and that the risk was "of such a nature and degree that, considering the nature and purpose of the actor's conduct and the circumstances known to him, its disregard involved a gross deviation from the standard of conduct that a reasonable person would observe in the actor's situation." The court determined that the charge should be tailored to the factual circumstances of the case. The court concluded that evidence of an actor's mistaken belief related to whether the State had failed to prove an essential element of the charged offense beyond a reasonable doubt.

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