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Name: People v. Mejia-Lenares
Case #: F045355
Court: CA Supreme Court
District 5 DCA
Opinion Date: 01/26/2006

Because imperfect self-defense cannot be based on a delusion alone, the court was not required to instruct the jurors to consider evidence regarding hallucinations. At his murder trial, the defendant presented evidence that he had stabbed the victim out of fear that the victim was transforming into the devil and wanted to kill him. The defendant also produced evidence regarding his mental illness at the time of the offense, including major depression with psychotic features and delusions. The trial court instructed the jury on imperfect self-defense, and also on the relevance of hallucinations to findings of premeditation and deliberation. The court refused to instruct the jury that the evidence of hallucinations could be considered as to the issue of imperfect self-defense, relying on People v. Padilla (2002) 103 Cal.App.4th 675, in which the court held that evidence of hallucinations could not serve to mitigate murder to voluntary manslaughter. The Court of Appeal found that the Legislature had not intended to extend imperfect self-defense claims to a defendant whose actual belief in the necessity of self-defense was based on a hallucination or delusion, and thus the trial court did not err in refusing the instruction.