People v. Brady
22 Cal.App.5th 1008, 232 Cal. Rptr. 3d 220 (2018)
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Rule of Law:
The objective reasonableness component of self-defense requires a defendant's belief of imminent bodily injury to be one that a person of ordinary and normal mental and physical capacity would hold under the known circumstances; it does not incorporate a defendant's unique mental conditions or past traumatic experiences that might increase a propensity to misperceive threats.
Facts:
- Charles Wesley Brady, a homeless individual in downtown San Diego, made money by selling hats, costume jewelry, and similar items on the street.
- Lincoln M., another homeless individual, became an acquaintance of Brady after purchasing silver jewelry from him, and Brady knew or strongly suspected Lincoln carried a knife, though they had never argued or fought previously.
- One night in January, Lincoln purchased two pieces of silver jewelry (a necklace and wristband) from Brady for $40.
- The next morning, Lincoln approached Brady and a friend near a trolley stop, demanding his $40 back for a necklace he claimed he had returned to Brady's partner, and twice threatened, 'Diemu, you need to give me my $40 back before I stick you with my kazoo.'
- Brady understood 'Diemu' to mean he was a Bloods gang member and 'kazoo' to mean a knife.
- While Lincoln fidgeted with his wallet and looked away from Brady, Brady touched or lightly pushed Lincoln on the chest several times before suddenly grabbing Lincoln's sweatshirt collar and thrusting a knife into his lower abdomen.
- The stab wound to Lincoln was approximately four centimeters long, pierced his abdominal cavity, and required a formal laparotomy surgery to repair.
Procedural Posture:
- Charles Wesley Brady was charged by a single-count information with assault with a deadly weapon, with allegations of personally using a dangerous weapon and personally inflicting great bodily injury, as well as prior strike and serious felony allegations.
- The case was tried to a jury in the trial court.
- The jury found Brady guilty of assault with a deadly weapon and found true the allegations that he used a dangerous and deadly weapon and personally inflicted great bodily injury.
- Brady admitted he had two prior strikes and that both were for serious felonies, and also admitted a prison prior.
- At sentencing, the trial court struck the prior strikes and prison prior allegations pursuant to section 1385.
- Brady was sentenced to 15 years in prison.
- Brady appealed his conviction to the California Court of Appeal, challenging the sufficiency of the evidence for the jury to reject his self-defense theory.
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Issue:
Does the objective reasonableness standard for self-defense incorporate a defendant's unique mental conditions and past traumatic experiences, such as bipolar disorder, PTSD, and a history of abuse, to determine whether their belief of imminent bodily injury was reasonable?
Opinions:
Majority - Dato, J.
No, the objective reasonableness standard for self-defense does not incorporate a defendant's unique mental conditions and past traumatic experiences that may cause them to misperceive threats. Justice Dato, writing for the majority, affirmed Brady's conviction, holding that the objective component of self-defense considers what would appear necessary to a reasonable person of ordinary and normal mental and physical capacity in the defendant's situation and with their knowledge, not a 'reasonable Brady' with his specific mental conditions and traumatic history. The court distinguished its precedents in People v. Humphrey (1996) and People v. Sotelo-Urena (2016), clarifying that those cases allowed evidence of unique circumstances (like intimate partner battering or chronic homelessness) only when such experiences increased a defendant's ability to accurately perceive actual threats, not to explain a propensity to misperceive threats due to conditions like bipolar disorder or PTSD. Citing People v. Jefferson (2004) and People v. Steele (2002), the court reaffirmed that the standard is not whether the defendant, or a person like him, had reasonable grounds, but whether a person of ordinary mental and physical capacity would have believed themselves in imminent danger. The court found sufficient evidence for the jury to reject Brady's self-defense claim on multiple grounds, including that he told police he was protecting property, not acting out of fear for his life, and video evidence showed Lincoln not being physically threatening while Brady acted more aggressively.
Analysis:
This case clarifies the limits of the 'defendant's perspective' within the objective reasonableness standard for self-defense in California. By distinguishing between factors that enhance a defendant's ability to accurately perceive danger (like the sensitivity gained from intimate partner battering or chronic homelessness) and factors that might lead to misperception (like mental illness or past trauma), the court reaffirms a narrower, more objective interpretation of the 'reasonable person.' This decision prevents the self-defense standard from becoming overly subjective, maintaining that a defendant's individual vulnerabilities, such as PTSD or bipolar disorder, cannot transform an objectively unreasonable act into a reasonable one, thereby limiting the scope of expert testimony in future self-defense claims.
