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Name: People v. Wright
Case #: S119067
Court: CA Supreme Court
District CalSup
Opinion Date: 05/26/2005
Subsequent History: rehng. den. 6/29/05
Summary

The Supreme Court granted review in this case to determine whether to extend the doctrine of imperfect self defense articulated in In re Christian S. (1994) 7 Cal.4th 768 to a case in which the defendant’s actual though unreasonable belief in the need to defend himself was based on delusions caused by mental illness or intoxication, without any objective circumstances of a threat. However, the court did not address the issue, finding that appellant was able to claim imperfect self-defense, the jury heard evidence supporting his defense, and the exclusion of additional evidence supporting the defense was not prejudicial to him. The Court reversed the judgment of the Court of Appeal, which had found prejudicial error in the exclusion of testimony from witnesses on whose statements the examining psychiatrist had relied in concluding that appellant suffered from delusions which supported his self-defense claim. The appellate court had found that the excluded testimony was crucial to substantiating appellant’s assertion of imperfect self-defense. The Supreme Court here found that the exclusion of the additional testimony arguably violated Evidence Code section 352, but that exclusion was harmless beyond a reasonable doubt. J. Brown concurred but called on the Legislature to provide clear definitions of malice and imperfect self defense.