State v. Barrett
The Supreme Court reversed the decision of the court of appeals ruling that the district court's error in denying Defendant's request for an instruction on imperfect self-defense voluntary manslaughter was harmless, holding that the error was reversible because there was a reasonable probability that it affected the trial's outcome.Defendant, who had schizophrenia, killed a man who entered his apartment to exterminate bugs because he felt irrationally threatened by the victim. At issue during trial was whether Defendant's mental condition precluded him from forming a culpable mental state. The jury found Defendant guilty of reckless second-degree murder. The court of appeals affirmed, holding that the district court erred when it failed to give a voluntary manslaughter instruction - an intentional killing done with the unreasonable but honest belief that circumstances existed justifying the deadly force - but that the instructional error was harmless under the so-called "skip rule." The Supreme Court reversed and remanded for a new trial, holding that the trial court's error in failing to give an imperfect self-defense voluntary manslaughter instruction was reversible because the jury could have reasonably convicted Defendant of voluntary manslaughter. View "State v. Barrett" on Justia Law