Mattie M. Evans v. United States
107 U.S. App. D.C. 324, 1 A.L.R. 3d 566, 277 F.2d 354 (1960)
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Rule of Law:
In a homicide trial where self-defense is claimed, evidence of the deceased’s character and belligerency, even if unknown to the defendant, is admissible to corroborate the defendant’s testimony that the deceased was the aggressor.
Facts:
- Around 5:30 a.m. on May 1, 1955, Appellant was with two other women and a man on a street in Washington.
- The group hailed the deceased, who was walking on the other side of the street, and he subsequently joined them.
- A few moments later, tussling and fighting began within the group, during which Appellant inflicted mortal wounds upon the deceased with a knife.
- The deceased was intoxicated at the time of the incident.
- Appellant testified that she killed the deceased in self-defense, claiming he sexually assaulted her, grabbed her, and ripped her clothing.
- Appellant carried a knife for protection and used it during the struggle.
- The deceased and Appellant were strangers, and there was no evidence of a robbery motive.
- Appellant's counsel offered testimony from the deceased’s wife that he was mentally ill, and at times, especially when drinking, would act belligerently and bellicosely.
Procedural Posture:
- Following a trial, the District Court convicted Appellant of second-degree murder.
- On January 18, 1956, the District Court entered judgment and sentenced Appellant to a prison term of five to twenty years.
- On January 23, 1956, Appellant applied to the District Court for leave to appeal in forma pauperis (as a poor person without paying court fees), which was denied.
- On January 27, 1956, Appellant renewed her application to the U.S. Court of Appeals for the D.C. Circuit (Misc. No. 619).
- On February 27, 1956, the U.S. Court of Appeals denied the petition "without prejudice to renewal upon a more adequate showing."
- On June 14, 1956, the U.S. Court of Appeals dismissed the appeal for failure to comply with procedural rules.
- On April 15, 1959, Appellant resubmitted an application to the U.S. Court of Appeals for leave to appeal in forma pauperis.
- On September 16, 1959, the U.S. Court of Appeals allowed Appellant to proceed on appeal in forma pauperis and appointed counsel to assist her.
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Issue:
Is evidence of the deceased's character for belligerency and aggression, unknown to the defendant, admissible to corroborate a self-defense claim that the deceased was the aggressor?
Opinions:
Majority - Bazelon, Circuit Judge
Yes, evidence of the deceased's character and belligerency, even if unknown to the defendant, is admissible to corroborate a self-defense claim that the deceased was the aggressor. The court reasoned that when self-defense is at issue and there's a controversy over who was the aggressor, the deceased's character can illuminate the probabilities of their actions, as noted by Professor Wigmore. The element of prior communication to the defendant is unnecessary because the inquiry focuses on the objective occurrence of events—what the deceased probably did—rather than the defendant’s subjective belief. The court found that the proffer, though inartful, sufficiently indicated that the deceased was aggressive when drunk, making it relevant given his intoxication at the time of the incident. Such evidence of the deceased's character would be highly relevant in helping the jury determine the veracity of Appellant's sexual assault claim, serving the interests of justice. The exclusion of this testimony was not harmless error, as even if the jury disbelieved parts of Appellant's testimony, the proffered evidence might have led them to believe her claim that the deceased was the aggressor, potentially resulting in an acquittal or a conviction for the lesser included offense of manslaughter rather than second-degree murder.
Dissenting - Fahy, Circuit Judge
No, the proffered testimony was too tenuously related to the specific self-defense claim (resisting a sexual assault) to justify reversing the conviction. Considering all the evidence regarding how the homicide occurred, the dissenting judge found the connection insufficient. Therefore, the possibility that the jury might have convicted the appellant of manslaughter instead of murder was not significant enough to warrant reversal.
Analysis:
This case significantly broadens the scope of admissible character evidence in self-defense cases by explicitly allowing evidence of the deceased's character for aggression, even if the defendant was unaware of it. It shifts the focus from the defendant's subjective state of mind to an objective assessment of who initiated the aggression. This ruling makes it easier for defendants to present a complete self-defense narrative, particularly when their own credibility is challenged, and could lead to more nuanced jury deliberations regarding the aggressor's conduct and potentially a conviction for a lesser offense.
