People v. Mills
California Supreme Court
55 Cal. 4th 663, 147 Cal. Rptr. 3d 833 (2012)
- Written by Arlyn Katen, JD
Facts
Ahkin Ramond Mills (defendant) repeatedly approached Jason Jackson-Andrade at a train station to curse at him and ask him whether he had a gun and wanted to kill him. Eventually, when Jackson-Andrade looked at Mills, Mills said, “Well, if you ain’t got no motherfucking gun, I do,” pulled a gun from his pocket, and shot Jackson-Andrade seven times while Jackson-Andrade tried to crawl away. Jackson-Arande died at the scene. Mills pleaded both not guilty and not guilty by reason of insanity to Jackson-Andrade’s murder. During the guilt phase of trial, Mills presented an imperfect self-defense claim, arguing that Mills should be guilty only of manslaughter because he held a good-faith, unreasonable belief that Jackson-Andrade presented an imminent threat. Mills testified that he believed that Jackson-Andrade was angry, threatening to kill him, and reaching for a gun in his pocket. Mills’s wife and cousin testified that Mills believed people were after him, radio commercials were speaking to him, and the FBI was following him in a FedEx truck. An expert psychologist testified that Mills had a delusional disorder that caused Mills to grow hypervigilant and misinterpret events as threatening. The trial court gave a jury instruction that conclusively presumed that Mills was sane at the time of the offense. The jury convicted Mills of first-degree murder. At the sanity phase of trial, the jury found that Mills was sane during the murder. Mills was sentenced to 50 years to life in prison. Mills appealed, arguing that the jury instruction improperly required the jury to presume the existence of a mental state that the government (plaintiff) was required to prove and brought the irrelevant issue of Mills’s sanity into the trial’s guilt phase. The California Court of Appeal affirmed the trial court, and Mills again appealed.
Rule of Law
Issue
Holding and Reasoning (Corrigan, J.)
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