State v. Baltazar
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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals reversing Defendant's conviction and remanding the case for a new trial, holding that trial counsel was not ineffective for failing to object to a jury instruction on the outdated version of the "stand your ground" justification and that the district court did not abuse its discretion in excluding character evidence of the victim.
A jury found Defendant guilty of murder. During trial, Defendant asserted the justification of self-defense and defense of others. On appeal, the court of appeals held (1) the district court did not abuse its discretion in excluding certain character evidence of the victim, (2) there was sufficient evidence to support the conviction, but (3) the outdated justification instruction was prejudicial. The Supreme Court vacated the court of appeals' decision in part and affirmed the judgment of the district court, holding (1) trial counsel was not ineffective for not objecting to the instruction because engaging in an illegal activity disqualified Defendant from asserting stand-your-ground justification; and (2) the character evidence at issue was properly excluded because Defendant was unaware of the victim's specific conduct.
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