State v. Elzey
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The Court of Appeals affirmed the judgment of the court of special appeals reversing Defendant's conviction of voluntary manslaughter and ordering a new trial, holding that the trial court erred in its formulation of the jury instruction on Battered Spouse Syndrome, and this error was not harmless beyond a reasonable doubt.
Defendant killed her boyfriend but claimed that she did so in self-defense. To support her theory of self-defense, Defendant introduced expert testimony concerning Battered Spouse Syndrome (the Syndrome). The jury acquitted Defendant of murder but convicted her of voluntary manslaughter. The court of special appeals ordered a new trial, concluding that the trial judge's instruction to the jury concerning the Syndrome was erroneous and that the error was not harmless beyond a reasonable doubt. The Court of Appeals affirmed, holding that the trial court erred in instructing the jury regarding the Syndrome and that the error was not harmless.
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