California v. Brady
Annotate this CaseDefendant Charles Brady stabbed a former customer following a “street side jewelry transaction gone awry.” Based on that incident, defendant was convicted of assault with a deadly weapon inflicting great bodily injury. By convicting Brady, the jury necessarily rejected his primary defensive theory: that he was acting in self-defense. On appeal, he defendant asserted no reasonable jury could reach that conclusion. While his argument ultimately challenged the sufficiency of the evidence underlying his conviction, before arriving there, the Court of Appeal found defendant raised an interesting question as to the relevant legal standard. Because the objective standard looks from "the defendant's perspective," Brady contended it should take into account his mental condition and past traumatic experiences. “Essentially, Brady argued that the relevant question is what a reasonable person with bipolar disorder, posttraumatic stress disorder, and his personal history would have done in the situation—i.e., what would a reasonable Brady do?” That, the Court determined, was not the proper standard. Applying the correct legal standard (as the jury did), the Court concluded sufficient evidence supported its rejection of Brady's self-defense theory for want of objective reasonableness. Moreover, there was sufficient evidence for the jury to repudiate his self-defense claim on other grounds. “The jury may have concluded that Brady was not acting out of actual fear for his life since, contrary to his testimony at trial, he told police officers shortly after the event that he was acting to protect his property and made no mention of protecting his person. Alternatively, the jury may have determined that any threat to Brady was not imminent or that the force he used was unreasonable, given that video surveillance showed Brady acting more aggressively than his victim.”
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