Tuesday, February 26, 2013

People v. Williams case brief

People v. Williams case brief summary
63 Cal. 2d 452

PROCEDURAL POSTURE: A jury found defendants guilty of second degree murder in connection with the stabbing of a man known as a methedrine supplier. Defendants claimed self-defense, alleging the victim pulled out a knife first. The Superior Court of the City and County of San Francisco (California) instructed the jury that it must find defendants guilty of second degree murder if the killing occurred during a conspiracy to obtain methedrine. Defendants appealed.

-On 11/4/1989, the victim stood outside a homeless shelter where she was staying.
-According to the victim, a resident at the shelter named Williams (D) approached her and asked her to get coffee.
-After spending the morning together, Williams asked her if she wanted to watch television.
-She agreed and he took her to a nearby hotel.
-The victim did not realize it was a hotel until Williams rented a room and requested a bed sheet. -They went into the room, which had no television set.
-The victim confronted Williams but he did not respond.
-He instead asked her to join him on the bed.
-The victim attempted to leave, but Williams physically blocked the door.
-He yelled at her, hit her in the eye, and threatened to hurt her if she did not cooperate.
-The victim cooperated and they engaged in sexual intercourse.
-Williams had an entirely different account from the victim.
-He said he did not go to the hotel room intending to have sex with her.
-However, when they got into the room, the victim began kissing him and taking off her clothes.
-He stated that the victim fondled him and initiated sexual intercourse.
-Afterwards, the victim left and reported the incident to police
-Defendants claimed that the evidence established, as a matter of law, that they acted in self-defense. -The court overturned the convictions.

First, courts may sometimes say the prosecution is "bound by" the extrajudicial statements of a defendant which are introduced by the prosecution and which are irreconcilable with guilt, but this concept is applicable only when there is no competent and substantial evidence which could establish guilt.

-Here, other competent and substantial evidence tended to prove that defendants did not act in self-defense.
-Second, a homicide that is a direct causal result of the commission of a felony inherently dangerous to human life, other than the six felonies enumerated in Cal. Penal Code § 189, constitutes at least second degree murder.
-The felony involved here, conspiracy to possess methedrine, was not inherently dangerous.
-The trial court erred, therefore, in instructing the jury it might convict defendants of second degree murder on the basis of the felony.
-The error was prejudicial since the jury might have found defendants guilty of voluntary manslaughter.

OUTCOME: The court reversed the judgment of conviction of second degree murder and remanded the cause for further proceedings.

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