People v. LeedsAnnotate this Case
Defendant, diagnosed a paranoid schizophrenic, was convicted of murder after shooting and killing his father and three other men whom he believed were conspiring to kill him. Pursuant to a plea agreement that precluded imposition of the death penalty, defendant entered pleas of guilty and not guilty by reason of insanity to four counts of first degree murder. The court concluded that defendant was legally insane when he killed the victims if, as a result of his delusion, the facts as he perceived them, even if erroneous, would entitle him to claim self-defense. The court held that an instruction on self-defense in the sanity phase must inform the jury that a defendant's delusion caused him to believe that he was in danger of great bodily injury or death that required the use of deadly force and that he would be legally justified in doing so. In this case, the court concluded that the trial court erred when it instructed the jury that to claim self-defense, defendant's beliefs also had to be reasonable. By definition, the beliefs of a paranoid schizophrenic may not be those of a reasonable person presented with the same facts. As to three of the victims, however, the error was harmless. However, defendant's father could have been perceived as an immediate threat. Accordingly, the court reversed as to that count. The court rejected defendant's other contentions of error.