California Landmark Cases on Self-Defense Killing
In a murder case, unless the People's evidence suggests the defendant killed in imperfect self-defense, the defendant is obligated to proffer evidence on this issue sufficient to raise a reasonable doubt of the defendant's guilt for murder. (People v. Rios (2000) 23 Cal.4th 450, at pp. 461-462.)
Rios stated, "If the issue of . . . imperfect self-defense is thus 'properly presented' in a murder case (Mullaney v. Wilbur (1975) 421 U.S. 684), the People must prove beyond reasonable doubt that these circumstances were lacking in order to establish the murder element of malice. . . . . In such cases, if the fact finder determines the killing was intentional and unlawful, but is not persuaded beyond reasonable doubt that imperfect self-defense was absent, it should acquit the defendant of murder and convict him of voluntary manslaughter. ." (Rios, at p. 462.)
This follows because evidence of imperfect self-defense sufficient to raise a reasonable doubt of the defendant's guilt for murder already has been presented to the trier of fact, and the People have not proven beyond a reasonable doubt imperfect self-defense was absent.
In determining whether error has been committed in giving or not giving jury instructions, an appellate court must consider the instructions as a whole and assume jurors are intelligent persons capable of understanding and correlating all given instructions. (Ibid.) Moreover, "'instructions should be interpreted, if possible, so as to support the judgment rather than defeat it if they are reasonably susceptible to such interpretation.' ." (Ibid.)
The ultimate question is whether there is a reasonable likelihood the jury applied the challenged instruction in an impermissible manner. (People v. Hajek and Vo (2014) 58 Cal.4th 1144, 1220.)