People v. Humphrey case brief

People v. Humphrey case brief summary
921 P.2d 1 (1996)

CASE SYNOPSIS

Defendant appealed from a judgment of the Court of Appeal of California, Fifth Appellate District, which affirmed a trial court judgment convicting defendant of voluntary manslaughter with personal use of a firearm.

CASE FACTS
Defendant shot and killed the man with whom she lived, allegedly out of fear that he was going to kill her. Defendant introduced expert and nonexpert testimony tending to prove that her state of mind was affected by battered women's syndrome. The trial court instructed the jury on second-degree murder, voluntary and involuntary manslaughter, and self-defense, stating that an actual and reasonable belief the killing was necessary was a complete defense, that an actual but unreasonable belief was a defense to murder but not voluntary manslaughter, and that battered women's syndrome was not relevant to the reasonableness of defendant's state of mind. The court of appeal affirmed defendant's voluntary manslaughter conviction.

DISCUSSION

• The supreme court reversed the conviction. 
• Evidence of battered women's syndrome was relevant to the reasonableness, as well as the subjective existence, of defendant's belief in the need to defend. 
• The evidence was also relevant to defendant's credibility. 
• To the extent it was relevant, the jury should have been allowed to consider it. 
• The contrary instruction was prejudicial error because it was reasonably probable that it affected the verdict adversely to defendant.

CONCLUSION
The court reversed the judgment of the court of appeal.

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