Brantley v. State

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Defendant, who was charged with voluntary manslaughter without also being charged with murder, was properly found guilty even where the State conceded the existence of sudden heat to support the standalone charge.On appeal, Defendant argued that the State was required to prove sudden heat and that the State’s concession rendered his self-defense defense illusory. The Court of Appeals reversed, ruling that the State failed to present sufficient evidence that Defendant acted with sudden heat. The Supreme Court granted transfer and affirmed the conviction, holding (1) although the jury was instructed that the State conceded the existence of sudden heat, there was evidence that Defendant acted in either sudden heat or self-defense, and therefore, the jury was presented with a classic question of fact; and (2) the State’s concession of sudden heat did not nullify Defendant’s claim of self-defense. View "Brantley v. State" on Justia Law