Sunday, November 17, 2013

State v. Hanton case brief

State v. Hanton case brief summary
614 P.2d 1280 (1980)

Defendant sought review of his manslaughter conviction from the Superior Court for King County (Washington).

Defendant was charged with manslaughter and he claimed the defense of self-defense. Defendant was convicted and on appeal contended that the self-defense instruction unconstitutionally placed on him the burden of proving self-defense.


  • The court agreed with defendant that the effect of the challenged instruction was to shift the burden of proof on self-defense to him. 
  • The court stated that proof of self-defense negated the element of recklessness in first degree manslaughter, and requiring accused to prove self-defense placed the burden of proving absence of recklessness on the accused. 
  • The court stated that such a result had been proscribed and it held that in a prosecution for first degree manslaughter the state bore the burden of proving absence of self-defense beyond a reasonable doubt. 
  • For future cases the court advised that if a defendant presented sufficient evidence to raise an issue of self-defense, the trial court need only instruct on it without allocating the burden of proof. 
  • The jury may then consider the evidence of self-defense in determining whether a defendant was acting recklessly. 
  • The lower court decision was reversed and the matter was remanded for a new trial.

The court reversed defendant's and remanded the cause for a new trial.

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