State v. Bringas
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The Supreme Court affirmed Defendant's conviction of second-degree murder for the death of a minor, holding that, contrary to Defendant's contention on appeal, the jury's answer to a special interrogatory was reconcilable with its verdict that Defendant was guilty of second-degree murder.
In its jury instructions, the trial court instructed the jury on the lesser included offenses of second-degree murder, including third-degree assault. The statute defining third-degree assault, Haw. Rev. Stat. 707-712, states that the offense may be reduced to a petty misdemeanor if the altercation is the result of "mutual affray." The circuit court submitted a special interrogatory to the jury on mutual affray and instructed the jury that it must answer the special interrogatory only if it found Defendant guilty of third-degree assault. The jury found Defendant guilty of second-degree murder and answered the special interrogatory in the negative. Defendant filed motion for a new trial, arguing that the jury's inconsistent verdict required that his convictions be vacated. The Supreme Court affirmed, holding that the evidence could have reasonably caused the jury to conclude that the altercation leading to the decedent's death began as mutual affray but ended in second-degree murder.
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