People v. Elmore
Annotate this CaseIf a defendant commits a killing out of an unreasonable belief in the need for self-defense, he or she may be convicted of voluntary manslaughter but not murder. After a jury trial in this case, Defendant was convicted of first degree murder. On appeal, the court of appeal rejected Defendant’s argument that the trial court erred in failing to instruct the jury on unreasonable self-defense, concluding that the doctrine does not apply when belief in the need for self-defense arises solely from the defendant’s delusional mental state. The Supreme Court affirmed, holding (1) at a trial on the question of guilt, the defendant may not claim unreasonable self-defense based on insane delusion, and a purely delusion belief in the need to act in self-defense may be raised as a defense, but that defense is insanity; and (2) because Defendant’s claim of unreasonable self-defense was based entirely on a delusional mental state that amounted to legal insanity, the trial court properly denied Defendant’s request for an instruction on unreasonable self-defense.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.