People v. Blakeley
23 Cal. 4th 82 (2000)
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Rule of Law:
Voluntary manslaughter is committed when a defendant, acting with conscious disregard for life and the knowledge that such conduct endangers the life of another, unintentionally but unlawfully kills while having an unreasonable but good faith belief in the need to act in self-defense; however, this unforeseeable judicial enlargement of the crime cannot be applied retroactively.
Facts:
- On October 25, 1994, George John Blakeley and his friend, David Fraire, were drinking brandy in a park before going to Blakeley’s home, where Steven Blakeley (George's brother), Tony Santiago, and Lionel Vallo were present.
- Vallo purchased $20 worth of methamphetamine from George Blakeley.
- Vallo, who had been drinking, commented that some methamphetamine he had recently bought from Santiago was 'bunk,' leading to a verbal exchange between Vallo and Santiago.
- George Blakeley told Santiago and Vallo to 'shut the fuck up,' to which Vallo responded, 'you shut the fuck up,' and Blakeley then told Vallo to leave the house.
- Vallo, who was six feet tall and weighed 205 pounds, swung a beer bottle at George Blakeley, who was five feet five inches tall and weighed 140 pounds, but missed.
- George Blakeley then hit Vallo in the head with an unopened beer bottle, which shattered and cut Vallo’s cheek.
- Vallo threw a beer bottle at Blakeley, missed, and then charged at Blakeley, who drew a large knife from a sheath on his belt.
- During the ensuing struggle, Vallo sustained a single stab wound to the chest, specifically to the heart, from which he bled heavily; Santiago pulled Vallo off Blakeley.
- Vallo died shortly after police and paramedics arrived; George Blakeley fled to his uncle’s home in San Bernardino, where his uncle subsequently called the police.
Procedural Posture:
- The trial court instructed the jury on the charged crime of murder and the lesser included offenses of voluntary and involuntary manslaughter.
- The trial court refused George Blakeley's requested instruction that an unintentional killing in an unreasonable but good faith belief in the necessity of self-defense constituted involuntary manslaughter.
- Instead, the trial court gave the standard CALJIC No. 8.45 instruction on involuntary manslaughter, which did not include unintentional killing in unreasonable self-defense, and CALJIC No. 8.40 on voluntary manslaughter, which stated that it required an intent to kill.
- The jury convicted George Blakeley of voluntary manslaughter.
- The Court of Appeal affirmed the conviction, reasoning that the 'unreasonable self-defense' doctrine had no special bearing on involuntary manslaughter and the trial court was not required to give the requested instruction.
- The California Supreme Court granted review.
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Issue:
Does an unintentional killing, committed with conscious disregard for life but an unreasonable good faith belief in the need for self-defense, constitute voluntary manslaughter, and if so, can this redefinition be applied retroactively to a defendant whose conduct occurred prior to this clarification?
Opinions:
Majority - Kennard, J.
Yes, an unintentional killing committed with conscious disregard for life but an unreasonable good faith belief in self-defense constitutes voluntary manslaughter. However, no, this clarification cannot be applied retroactively to George Blakeley's case. The court holds that voluntary manslaughter includes killings where a defendant, acting with conscious disregard for life, unintentionally but unlawfully kills in an unreasonable but good faith belief in the necessity of self-defense. This decision, following People v. Lasko, clarifies that an intent to kill is not a necessary element for all forms of voluntary manslaughter. The court reaffirms that implied malice, characterized by conscious disregard for life, cannot coexist with an actual belief, even if unreasonable, in the necessity of self-defense (In re Christian S., People v. Flannel). However, prior to this ruling, several Court of Appeal decisions (People v. Ceja, People v. Glenn, People v. Welch) had consistently held that an unintentional killing in unreasonable self-defense constituted involuntary manslaughter. Therefore, the court’s current holding — that such a killing is voluntary manslaughter rather than the less serious crime of involuntary manslaughter — represents an unforeseeable judicial enlargement of the crime. Applying this new interpretation retroactively to George Blakeley would violate constitutional prohibitions against ex post facto laws and due process guarantees (People v. Davis, United States v. Lanier, Bouie v. City of Columbia). Consequently, the trial court erred by refusing to instruct the jury that an unintentional killing in unreasonable self-defense was involuntary manslaughter, consistent with the prevailing understanding at the time of the offense. Nevertheless, this error was harmless under the People v. Watson test for prejudice. The jury was incorrectly instructed that voluntary manslaughter required an 'intent to kill' (an error that benefited the defendant by increasing the prosecution's burden), and both the prosecutor and defense counsel explicitly argued to the jury that an unintentional killing in unreasonable self-defense would be involuntary, not voluntary, manslaughter. Given these circumstances, it was not reasonably probable that Blakeley would have obtained a more favorable outcome if the trial court had given the specifically requested instruction on involuntary manslaughter.
Dissenting - Mosk, J.
No, the trial court erred reversibly by refusing to instruct the jury that the doctrine of imperfect self-defense could allow for a verdict of involuntary manslaughter. Justice Mosk argues that provocation (reducing murder to voluntary manslaughter) and imperfect self-defense operate differently. Provocation effectively reduces malice aforethought to a less culpable mental state, but imperfect self-defense, which lacks a direct statutory basis, can actually preclude the existence of malice aforethought itself. An actor's actual, albeit unreasonable, belief in imminent danger of death or great bodily injury, as established by Christian S. and Flannel, means they do not act with the 'deliberate and wrongful intent to kill' (express malice) or with a 'wanton disregard for human life' (implied malice). If malice aforethought is absent due to this belief, and there is no intent to kill (which prior interpretations required for voluntary manslaughter), then the killing cannot be voluntary manslaughter. In such a scenario, an actor who entertains an unreasonable belief in self-defense acts 'without due caution and circumspection,' thereby satisfying the mental state for involuntary manslaughter. Because the doctrine of imperfect self-defense, in his view, can negate the requisite mental state for voluntary manslaughter, the only remaining classification for an unlawful killing would be involuntary manslaughter. Justice Mosk concludes that the trial court's failure to give the requested instruction on involuntary manslaughter, given the equivocal evidence surrounding the fatal blow and the defendant's state of mind, constituted reversible error under the People v. Watson test because there was at least a 'reasonable chance' it affected the jury's verdict.
Analysis:
This case is highly significant as it clarifies and expands the definition of voluntary manslaughter in California, explicitly including unintentional killings where a defendant acts with conscious disregard for life but under an unreasonable good faith belief in self-defense. This ruling, alongside People v. Lasko, definitively established that intent to kill is not a universally required element for voluntary manslaughter. Furthermore, the decision strongly reaffirms the constitutional principle against ex post facto laws, preventing the retroactive application of unforeseeable judicial enlargements of criminal statutes to a defendant's detriment. For law students, this case illustrates the evolving interpretation of mental states in homicide law, particularly the interaction between malice aforethought, imperfect self-defense, and the distinction between voluntary and involuntary manslaughter. It also provides a critical example of how constitutional due process can limit the retroactive application of new legal principles, ensuring fairness for defendants based on the law as it existed at the time of their actions.
