In People v. Conkling (1896) 111 Cal. 616, the victim put up a fence to stop neighborhood residents from crossing his land on their way to the post office. When the defendant attempted to cross the victim's land, the defendant was confronted by the victim who, after a heated argument, would not permit the defendant to continue. Days later the defendant armed himself with a rifle and, in the victim's absence, tore down the fence. Yet a few days later, the defendant, again armed with the rifle, was returning from the post office across the victim's land when the victim confronted him. Trouble arose between the two and the defendant fatally shot the victim. Other than the defendant, there were no witnesses to the shooting. (Conkling, supra, 111 Cal. at pp. 619-621) The defendant was charged with murder and claimed self-defense. Part of the trial court's instructions to the jury on self-defense stated the jury could infer that if, prior to the shooting, the defendant provoked a quarrel or was the cause of a danger he had brought upon himself, such conduct would forfeit his right to a claim self-defense. (Conkling, supra, 111 Cal. at pp. 624-625.) The Supreme Court found the instruction was reversible error because there was no evidence to show defendant initiated a quarrel or had brought danger upon himself; accordingly, there was no evidence to support the instruction. (Id. at pp. 625-626, 628.)