People v. Benitez

Around 1989, Pedro Aguilar Benitez (defendant) immigrated from Mexico to the United States and entered a common-law marriage with Sandra Castrejon. Benitez was abusive toward Castrejon and was convinced that she was romantically involved with his 19-year-old son. On the morning of August 20, 2000, Castrejon tried to terminate her relationship with Benitez before leaving for work and told him to leave the family home. When Castrejon returned from work, Benitez was still at the home and begged her to take him back. Castrejon refused and went to stay with her sister for a few hours. When Castrejon returned, Benitez was still at the home. Castrejon and Benitez began arguing. Benitez then told Castrejon that he did not want anyone else to have her. Benitez retrieved a knife from the kitchen and began stabbing Castrejon to death. During multiple police interviews, Benitez made statements that indicated the killing was premeditated. The State of California (plaintiff) charged Benitez with Castrejon’s death. At trial, Benitez sought to introduce expert testimony from a psychologist to show that his thought process and response to jealousy was different from that of an Anglo-American man. Benitez’s purpose of introducing this testimony was to show that he had killed Castrejon out of passion after a reasonable provocation so that he would be found guilty of voluntary manslaughter instead of first-degree murder. The trial court excluded the evidence on the ground that a different reasonable-provocation standard based on one’s culture did not exist. Benitez was convicted of first-degree murder. Benitez appealed on the ground that, because he was unable to introduce the evidence, he was denied his rights to due process and a fair trial.