New Mexico v. Skippings
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The issue presented in this appeal was whether Defendant's requested involuntary manslaughter jury instruction was properly denied by the district court. Defendant Clinton Skippings was convicted in a jury trial of voluntary manslaughter. Defendant's conviction arose from a series of interactions with Christy Rogers (Victim) that ultimately culminated in her death. At Defendant's trial, the jury was instructed regarding second degree murder and voluntary manslaughter. The district court denied Defendant's requested involuntary manslaughter instruction. The jury returned a conviction on the voluntary manslaughter charge. Upon review of the trial record and the applicable legal authority, the Supreme Court concluded that where there is sufficient evidence of both criminal negligence and accident, it is proper to grant an involuntary manslaughter instruction. The Court affirmed the decision of the Court of Appeals, which found that the district court improperly denied the instruction. The Court reversed the appellate court and remanded the case for further proceedings.
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