State v. Faulkner
301 Md. 482, 483 A.2d 759 (1984)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A defendant's subjectively honest but objectively unreasonable belief that they are in imminent danger of death or serious bodily harm negates the element of malice, mitigating a homicide from murder to voluntary manslaughter. This doctrine of 'imperfect self-defense' also applies to assault with intent to murder, reducing the offense to simple assault.
Facts:
- Melvin J. Faulkner, Jr. and Jimmy Emanuel got into an argument outside a bar in Baltimore City.
- The argument escalated into a physical fight between Faulkner and Jimmy.
- Faulkner believed that Jimmy was armed with a knife and intended to inflict serious harm upon him.
- In response to this belief, Faulkner produced a handgun and began firing.
- Faulkner shot Rickey Emanuel, Jimmy's brother, twice in the chest as Rickey was trying to push Jimmy out of the line of fire.
- Testimony at trial established that Jimmy did, in fact, have an open pocket knife in his back pocket during the altercation.
Procedural Posture:
- Melvin J. Faulkner, Jr. was charged with assault with intent to murder and related handgun offenses in the Criminal Court of Baltimore.
- At trial, the court refused Faulkner's request for a jury instruction on the defense of 'imperfect self-defense'.
- The jury convicted Faulkner of assault with intent to murder and the handgun offenses.
- Faulkner, as appellant, appealed to the Court of Special Appeals of Maryland, an intermediate appellate court.
- The Court of Special Appeals reversed the conviction, holding that the trial court erred by refusing to give the requested jury instruction.
- The State, as petitioner, was granted a writ of certiorari by the Court of Appeals of Maryland, the state's highest court, to review the lower appellate court's decision.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does Maryland law recognize the doctrine of imperfect self-defense, where a defendant's subjectively honest but objectively unreasonable belief that deadly force was necessary for self-protection serves to mitigate murder to manslaughter, and if so, does this doctrine apply to the crime of assault with intent to murder?
Opinions:
Majority - Cole, J.
Yes, Maryland law recognizes the doctrine of imperfect self-defense, and it applies to the crime of assault with intent to murder. The court holds that a defendant who acts with a subjectively honest but objectively unreasonable belief that their actions were necessary for their safety lacks the malice required for a murder conviction. While perfect self-defense (which requires a reasonable belief) results in a complete acquittal, imperfect self-defense mitigates the crime from murder to voluntary manslaughter because the defendant is still culpable for their unreasonable assessment of the danger. Since the statutory crime of assault with intent to murder incorporates the common law elements of murder, any defense that negates malice in a murder case, such as imperfect self-defense, must also apply to this offense, reducing it to simple assault.
Analysis:
This landmark decision formally adopts the doctrine of imperfect self-defense into Maryland's common law, creating a crucial middle ground between a full murder conviction and a complete acquittal. The ruling emphasizes the importance of the defendant's subjective mental state in determining culpability, specifically by negating the element of malice. This holding significantly impacts criminal defense strategies in homicide cases, requiring trial courts to provide a jury instruction on this mitigating defense whenever the evidence supports a defendant's honest but unreasonable belief in the need for self-protection. By extending the doctrine to assault with intent to murder, the court ensures consistency in how defenses that negate malice are applied across related offenses.
Unlock the full brief for State v. Faulkner