United States v. James

Facts

At the time of the homicide, Defendant-Appellant was the girlfriend of the deceased; there was a long and violent history between Defendant-Appellant, the deceased, and Defendant-Appellant’s daughter, Jeffries. The homicide occurred outside a party Defendant-Appellant attended with Jeffries, the deceased, and Jeffries’ boyfriend, Michas Tiatano (Tiatano), after the deceased assaulted Tiatano and knocked him unconscious. The gun that was used in the homicide was given to Jeffries by Defendant-Appellant, as admitted by both parties. Jeffries asserted in her testimony, but Defendant-Appellant denied, that Defendant-Appellant showed Jeffries how to turn the “safety” mechanism off the gun. The charge of aiding and abetting manslaughter was based on Defendant-Appellant’s action of handing the gun to Jeffries, when Defendant-Appellant was seated in a car and the decedent was outside the car. Defendant-Appellant’s attorney was disallowed from showing the following to the jury at trial, and the prohibition of the following is the basis for the appeal: Court documents setting forth detailed findings on the robbery of a 58-year old man, in which the decedent sat on the man and held a knife at his throat and at his eyes while threatening to blind him; A pre-sentence report with 38 priors, some resulting in conviction, some with unknown dispositions; A Seattle police report that the decedent, with his shirt off, was randomly striking people in a crowd on Second Avenue in Seattle, near Pike Place Market; and A Seattle police report that, again near Pike Place Market, Ogden and another man grabbed a stranger, threw him down, beat him, and kicked him in the face. The trial judge disallowed the preceding evidence because the evidence was unknown to Defendant-Appellant and therefore irrelevant to the defense of self-defense; the only relevant evidence to that defense is what Defendant-Appellant was aware of at the time the gun was given to Jeffries.