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Name: People v. Bates
Case #: C086471
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 05/07/2019
Summary

Because the defendant was unaware of the victim’s prior threatening conduct, such conduct was not relevant to show defendant’s state of mind for purposes of self-defense. During defendant’s murder trial, several witnesses testified about past events in which the victim made threats and brandished a gun in a menacing manner. There was no evidence that defendant knew about these threats prior to the homicide. Defendant requested a self-defense instruction specifically stating that the jury could consider the victim’s past threats or harm to defendant or others in deciding whether the defendant’s conduct and beliefs were reasonable. The trial court denied the request, finding that defendant had to know of the victim’s prior threatening conduct before it could instruct the jury as requested. The jury convicted defendant of voluntary manslaughter, and he appealed. Held: Affirmed. Evidence that a victim had previously threatened or harmed others is relevant to a defendant’s claim of self-defense only if the defendant knew of the victim’s prior threatening conduct. (People v. Tafoya (2007) 42 Cal.4th 147, 165-166.) The defendant’s state of mind is a critical issue to determine the reasonableness of his actions, and he may explain his actions in light of his knowledge concerning the victim. Here, the trial court properly instructed the jury that to determine whether defendant’s beliefs were reasonable, it had to consider all the circumstances as they were known to and appeared to the defendant. Because no evidence showed that the victim had threatened defendant or that defendant knew the victim had previously threatened others, the trial court properly refused to give the more specific instruction. Whether the defendant’s conduct or belief was reasonable when the defendant had no knowledge of the victim’s violent character is an entirely different issue than the admissibility of the evidence of prior threats to show a victim’s conformity with a violent character.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/archive/C086471.PDF