People v. Pickerin

276 P.3d 553 (2011)

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Nature of the Case

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Facts

D and his friend, Bates, went to the apartment of another friend, Morgan, where Morgan and two other men, Villarreal and Torres, were present. An argument ensued between D, Bates, Morgan, and Villarreal, leading to a fight during which D allegedly stabbed Villarreal to death. D was charged with second-degree murder. D claimed to have acted in self-defense. The trial court gave a jury instruction on second-degree murder, which required P to prove beyond a reasonable doubt that D had knowingly caused Villarreal's death and that D did not act in self-defense. The trial court gave another instruction on the lesser-included charge of reckless manslaughter, which required P to prove beyond a reasonable doubt that D recklessly caused Villarreal's death. The latter instruction made no mention of self-defense. The jury found D guilty of reckless manslaughter and D appealed to the court of appeals. The court of appeals reversed. The court of appeals concluded that the instruction could have led the jury to misunderstand the relationship between recklessness and self-defense and find D guilty of reckless manslaughter even if it concluded that P failed to prove that he did not act in self-defense. P appealed.