Last week the Supreme Court of California ruled on whether a defendant can bring an “unreasonable self-defense” claim based on his delusional mental state at the time of the murder. In People v. Elmore the Court refused to give the jury an instruction of voluntary manslaughter based on an imperfect self-defense. The California Supreme Court Majority stated that, “California cases reflect the understanding that unreasonable self-defense involves a misperception of objective circumstances, not a reaction produced by mental disturbance alone.” The majority went on to give a definition between misperception and a delusion: “A delusional defendant holds a belief that is divorced from the circumstances. The line between mere misperception and delusion is drawn at the absence of an objective correlate.” In the instant case, the court concluded that the defendant Elmore was acting on a delusion devoid of any correlating facts when he attacked the victim.
The facts of the case were as follows: Defendant Elmore was mentally ill and diagnosed with schizophrenia; on several previous occasions the defendant had been diagnosed as psychotic and hospitalized. The defendant was living in a rehabilitation center and on the day of the murder. The defendant was visiting family when he began to act “fidgety and anxious.” The defendant ran away from his family members and was seen attacking the victim, Ella Suggs, whom he stabbed with a sharpened paint brush handle resulting in her death. The defendant grabbed the victim’s necklace before running away. At trial the defendant gave confusing testimony about the event and about what he remembered. He claimed part of the events of that day he had blacked out and did not remember who -- but knew someone -- threatened him. At trial the defendant wanted an instruction to be given to the jury of unreasonable self defense based on his delusions. The trial court denied the defendant’s motion. At sentencing, he withdrew his plea of not guilty by reason of insanity and was sentenced to 25 years to life for first degree murder. The Supreme Court ruled that the defendant was not entitled to the instruction and the conviction of 1st degree murder must stand. The court reasoned that the defense did not present any evidence that Elmore acted on some misperception of fact in defending himself from a threat, but rather, was delusional about the threat.