People v. Crane

Facts

David Crane (Defendant) was arrested on traffic violations in New Mexico, but because there was a notice of his probation violation and an outstanding warrant for him in relation to the murder of Robert Gahan in Illinois, he was arrested and held there. Thereafter, Illinois detectives Roger Costello and Larry Schultz interviewed Defendant in New Mexico about his relationship to Gahan. Defendant told the detectives that he had been hitchhiking and that Gahan gave him a ride. While driving, Defendant said Gahan asked him if he wanted to smoke some marijuana. Defendant said he did. Defendant directed Gahan to a secluded area where they parked, got out, and began smoking the marijuana. Thereafter, Gahan began to choke Defendant. Defendant reacted by repeatedly striking Gahan with numchucks until he fell to the ground. Thinking Gahan was dead Defendant took the car to a friend’s house and told him what had happened. Defendant’s friend told him to destroy the evidence. Defendant returned to where Gahan was, poured gasoline over him, and lit him on fire. Defendant later learned that Gahan may not have been dead at the time of the burning. Defendant was charged with two counts of murder. Both counts alleged that Defendant beat and burned Gahan, thereby causing his death. Count I charged that Defendant acted “with intent to kill or do great bodily harm."Count II charged that Defendant acted “knowing such acts created a strong probability of death or great bodily harm."At trial, Defendant requested that the jury be instructed on self-defense as well his primary theory of defense, mistake of fact. The trial court instructed the jury on self-defense but refused to give the requested mistake of fact instruction. Defendant was convicted and he appealed. The appellate court reversed the conviction and the Illinois Supreme Court granted review.