State v. Elzey

One evening, an argument arose between Latoya Elzey (defendant) and her boyfriend, Migail Hunter, while they were staying at a friend’s house. The friend heard a slapping sound followed by Elzey telling Hunter to stop hitting her. Shortly thereafter, an upset Elzey entered the kitchen, grabbed a butcher knife, and returned to the living room. The arguing continued, and the friend, who was in the kitchen, heard Hunter taunting Elzey, saying that Elzey would have to do what she had to do. When the friend heard a thump, she entered the living room and found Hunter on the floor. Elzey claimed he had walked into the knife. Hunter died from his injuries, and Elzey was charged with murder. At trial, Elzey claimed self-defense. She testified that Hunter was possessive and frequently physically abused her. Elzey also testified about abuse from previous relationships. Further, a psychiatrist testified that because of childhood abuse and domestic violence by three partners, including Hunter, Elzey suffered from battered-spouse syndrome. In the trial court’s jury instruction on battered-spouse syndrome, the court stated that the jury was required to first determine whether Elzey had suffered repeated abuse from Hunter and, if so, whether she suffered from battered-spouse syndrome. Then, the jury could consider evidence of the syndrome in determining Elzey’s state of mind to decide whether self-defense applied. The jury acquitted Elzey of murder but convicted her of voluntary manslaughter. Elzey appealed, arguing that the jury instruction (1) erroneously required the jury to find that Elzey had suffered repeated abuse by Hunter before it could consider evidence of abuse by others and the effects of battered-spouse syndrome and (2) was confusing regarding the relevance of Elzey’s abuse by others. The appellate court agreed with Elzey, and the state appealed.