State v. Hanton
Supreme Court of Washington
614 P.2d 1280 (1980)
- Written by Craig Conway, LLM
Facts
While driving his vehicle, Solomon Hanton (defendant) swerved in front of another car and cut the driver off, causing the driver to apply his brakes to avoid a collision. The other man became quite angry and closely followed Hanton until they reached a stoplight. After both cars stopped, the other man got out of his car, went to Hanton’s car and opened the driver’s side door and attempted to pull Hanton out of the vehicle. Hanton then drew a pistol and shot the man who died several days later. Hanton was charged with first-degree manslaughter while armed with a deadly weapon. At the close of the evidence the trial court instructed the jury “[w]hen a defendant claims he killed another in defense of his person or property, the burden is upon that defendant only to produce some evidence tending to prove that the homicide was done in self-defense. It is not necessary for the defendant to prove this to you beyond a reasonable doubt, nor by a preponderance of the evidence. The defendant sustains this burden of proof, if from a consideration of the evidence in the case you have a reasonable doubt as to whether or not the killing was done in self-defense.” Hanton was found guilty and he appealed. The court of appeals affirmed the conviction and the Supreme Court of Washington granted review.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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