People v. Hendrix
California Supreme Court
13 Cal. 5th 933 (2022)
- Written by Eric Miller, JD
Facts
Early one morning, Isaiah Hendrix (defendant) walked up to a house and rang the doorbell. Receiving no answer, Hendrix walked to the back of the house and tried to open a locked door. The homeowner called the police. Hendrix claimed that he was looking for a cousin whom he believed lived in the house. Hendrix was charged with burglary. At trial, the prosecution introduced evidence to cast doubt on Hendrix’s purported justification. This included testimony from the manager of a nearby store who said that Hendrix had used an excuse of looking for a relative as a pretext for stealing from the store. The jury was instructed that Hendrix’s culpability hinged on his state of mind—that he was guilty if he intended to commit burglary and not guilty if he genuinely and reasonably believed the home to belong to his cousin. Hendrix was found guilty. However, the reasonableness element of the mistake-of-fact instruction was contested on appeal. Both sides agreed that the instruction was erroneous in that a mistaken belief by Hendrix needed to be genuine, but not necessarily reasonable. The issue was whether the erroneous instruction was prejudicial. The appeals court determined that it was not. The question then went to the California Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Kruger, J.)
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