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Wilson v. Tard

United States District Court for the District of New Jersey
593 F. Supp. 1091 (1984)


Facts

Christopher Wilson (defendant) shot and killed his friend Rodney Brown. Wilson was charged with manslaughter. At trial, Wilson raised the defense of mistake of fact, stating that he was unfamiliar with the gun and thought he had disarmed it before pointing it at Brown. However, the gun still had one bullet, which discharged and killed Brown when Wilson pulled the trigger. Wilson argued that his mistake was reasonable and that it negated the mental state of recklessness necessary for a manslaughter conviction. The trial judge instructed the jury that it was Wilson’s burden to prove his defense by a preponderance of the evidence. The jury found Wilson guilty of simple manslaughter. Wilson appealed on the grounds that the burden of proving his defense had been placed on him in error. The appeals court affirmed the trial court’s judgment, finding that as a matter of law, pointing a gun at another person and firing the gun constituted recklessness. Wilson appealed to the United States District Court.

Rule of Law

Issue

Holding and Reasoning (Stern, J.)

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