People of Guam v. A-Last Amanto Simiron, 2021 Guam 16

Victim Gilbert Alvarez was found at UOG with severe facial and skull trauma; autopsy ruled death from basilar skull fracture and facial lacerations.
Simiron (defendant) and co-defendant Sally were connected to the scene; Simiron gave written and recorded statements admitting he grabbed Alvarez in a rear-naked chokehold, punched him, disarmed a pipe, and told Sally to strike Alvarez repeatedly.
Forensic evidence (DNA and a fractured tooth with zinc) tied Alvarez’s blood to the truck, scene, and portions of Simiron’s clothing and supported use of a metal pipe.
The trial court instructed the jury on self-defense and defense-of-another but did not explicitly state the People bore the burden to disprove defense-of-another beyond a reasonable doubt; it gave an intoxication instruction but limited its application and declined to apply it to murder and manslaughter.
Jury convicted Simiron of Murder (1st degree), Manslaughter (1st degree), multiple assault counts, and theft; Simiron appealed arguing (1) plain error in the defense-of-another instruction and (2) abuse of discretion in refusing to apply the intoxication instruction to murder and manslaughter.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Simiron)	Held
Failure to instruct jury that People must disprove defense-of-another beyond a reasonable doubt (plain error)	Any instructional omission does not prejudice Simiron because evidence overwhelmingly shows Alvarez was not the initial aggressor and Simiron’s force was excessive	Trial court failed to inform jury the prosecution bore burden to disprove defense-of-another and to instruct that acquittal is required if prosecution failed that burden	Court: Instructional omission was clear and obvious error, but no effect on Simiron’s substantial rights given overwhelming evidence against justification; conviction affirmed
Whether voluntary (self-induced) intoxication instruction should apply to murder and manslaughter (abuse of discretion)	Intoxication inapplicable because the charged offenses required recklessness and statute treats self-induced intoxication as not negating recklessness	Intoxication evidence can be used to negate mens rea and therefore should apply to murder/manslaughter	Court: No abuse of discretion — under governing intoxication provisions, self-induced intoxication does not negate recklessness, so instruction properly excluded for those counts

United States v. Jackson, 726 F.2d 1466 (9th Cir. 1984) (instruction must be given when evidence could rationally sustain a defense)
United States v. Doe, 705 F.3d 1134 (9th Cir. 2013) (jury instructions must be supported by law)
State v. Flewelling, 524 A.2d 765 (Me. 1987) (self-induced intoxication does not negate recklessness)
State v. Trieb, 315 N.W.2d 649 (N.D. 1982) (intoxication statute prevents exculpation when recklessness is the culpable mental state)
Barton v. Superior Court, 906 P.2d 531 (Cal. 1995) (trial court need not present every conceivable defense; instruction required only where supported by evidence)