New Mexico v. Sandoval
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Defendant Timothy Sandoval was convicted of the second-degree murder of Jeff McCormick. The central issue at trial was whether McCormick was a mere bystander or an actual participant with the two other men involved in an altercation that ended with his death. The Court of Appeals determined that the "self-defense" and "defense of another" jury instructions issued at Defendant's trial constituted fundamental error because the instructions failed "to adequately and accurately describe Defendant's theory of defense" and misstated the applicable law. Upon review of the trial record and the applicable legal authority, the Supreme Court found that the instructions were not a correct statement of the law, but because the jury could have found that Defendant acted in self-defense and defense of another without considering McCormick as an assailant, the trial court's use of the instructions did not constitute fundamental error. The Court reversed and remanded the case for further proceedings with the appellate court.
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