What Actions of An Individual Determine That He Has Committed Voluntary Manslaughter ?
In People v. Blakeley (2000) 23 Cal.4th 82, the defendant was charged with murder in the stabbing death of the victim.
The defendant had been drinking with others at his home.
An argument broke out about the quality of some methamphetamine the victim bought from the defendant. the defendant ordered the victim to leave the house.
Instead, the victim, who was much taller and heavier than the defendant, swung a beer bottle at the defendant but missed.
The defendant smashed a bottle of beer on the victim's head cutting his cheek.
The victim threw a bottle at defendant but missed.
When the victim charged at the defendant, the defendant pulled out a large knife.
After a struggle, the victim was bleeding from a stab wound and died shortly thereafter.
The defendant fled the scene.
At trial, the testimony varied among the eyewitnesses from a deliberate stab as soon as the victim charged to a short struggle after the victim charged.
The defendant testified that he drew his knife in self-defense, that when he struggled with the victim they hit the floor and the victim fell on the knife. (23 Cal.4th at pp. 85-86.)
The trial court in Blakeley instructed on murder and the lesser offenses of voluntary and involuntary manslaughter, giving the standard instruction on involuntary manslaughter (CALJIC No. 8.45) (23 Cal.4th at pp. 86-87.)
The court refused a defense requested instruction "that a killing is involuntary manslaughter when the killer, acting in an unreasonable but good faith belief in the necessity of self-defense, unintentionally causes the victim's death." (Id. at p. 86).
Convicted of voluntary manslaughter (23 Cal.4th at p. 87), the defendant contended that he was guilty only of involuntary manslaughter in that he "unintentionally and unlawfully killed in unreasonable self-defense." ( Id. at p. 88.)
The defendant's argument was based on the premise that voluntary manslaughter required an intent to kill. ( Id. at p. 89.)
Blakeley determined that a defendant commits voluntary manslaughter "when he, acting with conscious disregard for life and the knowledge that the conduct is life-endangering, unintentionally but unlawfully kills while having an unreasonable but good faith belief in the need to act in self-defense." (23 Cal.4th at pp. 85, 88-89.)