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People v. Newton

(1970)

Court of Appeal of the State of California - 87 Cal. Rptr. 394, 8 Cal. App. 3d 359

tl;dr:

Defendant was shot in abdomen, then shot and killed police officer while unconscious from shock of abdominal wound. Not guilty of homicide because unconscious

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Case Summary

In the 1970 case People v. Newton, the California Court of Appeal overturned the voluntary manslaughter conviction of Huey P. Newton, co-founder of the Black Panther Party, for killing a police officer during a traffic stop. The court ruled that the trial judge made a harmful mistake by not informing the jury about the defense of involuntary unconsciousness, which Newton argued was due to being shot in the abdomen by another officer. This case is important because it demonstrates the legal concept that involuntary unconsciousness can be a full defense against a criminal homicide charge, as it eliminates the need for intent or malice. The court acknowledged that unconsciousness doesn't necessitate a coma or an inability to act, but can occur when someone acts without realizing it. The court also held that it is up to the jury to decide if the unconsciousness defense is supported by evidence, and that the trial judge must instruct the jury on this defense if requested by the defendant. The case also reflects the political and social climate of the late 1960s, marked by racial tensions and clashes between law enforcement and civil rights activists.

ICRAIssue, Conclusion, Rule, Analysis for People v. Newton

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Facts & HoldingPeople v. Newton case brief facts & holding

Facts:Huey P. Newton (defendant) was stopped by the police while...

Holding:While evidence is conflicting, some of it points to Newton...

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People v. Newton | Case Brief DeepDive
Majority opinion, author: RATTIGAN, J.
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The defendant, Huey P. Newton, is appealing a conviction of voluntary manslaughter and a prior felony conviction for assault with a deadly weapon. The defendant claims that the trial court erred by failing to instruct the jury on unconsciousness as a defense to criminal homicide. The defendant argues that the trial court made an error in not allowing the case to be reopened, and the prosecution violated the defendant's Sixth Amendment right of confrontation by reading the grand jury testimony of a witness who could not recall it to the trial jury without the opportunity for cross-examination. The defendant's prior felony conviction was affirmed by the court, and the trial court denied the defendant's motion to strike it from the indictment and for a protective order to prevent its mention at trial, claiming ineffective waiver of counsel. The defendant cannot challenge the validity of the indictment on the ground of unconstitutional discrimination. The court found other claims of trial error to be sustained, but the error in the instructions alone requires reversal.

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People v. Newton

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