State v. LaVallee-Davidson
Annotate this CaseDefendant Malcolm LaVallee-Davidson killed a man by putting a gun to his head and pulling the trigger during consensual sexual activity. At trial, Defendant argued that he did not know that the gun was loaded. The trial court convicted him of manslaughter. On appeal, Defendant argued that the trial court committed obvious error in its jury instructions and that the evidence was insufficient for a jury to find beyond a reasonable doubt that Defendant caused the death of the victim either recklessly or with criminal negligence. The Supreme Court affirmed the judgment, holding (1) the court's jury instructions correctly explained the mistake-of-fact statute and contained neither error nor obvious error, and (2) there was sufficient evidence for the jury to conclude beyond a reasonable doubt that Defendant caused the death of the victim and acted either recklessly or with criminal negligence.
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.