People v. Elmore, 59 Cal. 4th 121

Defendant, diagnosed with schizophrenia and repeatedly institutionalized, killed Ella Suggs at a bus stop after an episode at his grandmother’s home.
The stabbing occurred with a sharpened paintbrush handle; Suggs died from a stab to the chest/lung area, and certain personal items of Suggs were missing.
Defendant was charged with first-degree murder; at trial, experts debated whether he was actively psychotic when the stabbing occurred.
Defendant requested instructions on unreasonable self-defense, mistake of fact, and the effect of hallucination on murder degree; the court denied these requests.
Jury convicted of first-degree murder; defendant argued on appeal that he was entitled to an instruction on unreasonable self-defense; the Court of Appeal rejected that argument but remanded on hallucination issues.
This court held that purely delusional self-defense is not a basis for unreasonable self-defense at the guilt phase and must be raised in insanity proceedings under section 28(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether unreasonable self-defense can be based on delusional belief	Mejia-Lenares supports non-applicability when delusions predominate	Delusional self-defense can negate malice at guilt stage	Delusional self-defense not allowed at guilt phase
Interplay between section 28(a) and insanity	Evidence of mental illness to negate malice allowed under 28(a)	Section 28(a) allows diminished actuality evidence at guilt phase	Section 28(a) limited; insanity raised in sanity phase; delusional self-defense reserved for insanity
Can purely delusional beliefs negate malice at guilt phase	Delusion may negate malice if tied to self-defense	Delusion constitutes insanity; should negate at guilt phase	Purely delusional self-defense is insanity, not imperfect self-defense; not used to reduce guilt at guilt phase
Effect of hallucinations on degree of murder	Hallucinations may reduce degree via imperfect self-defense	Hallucinations evidence supports imperfect self-defense	Insanity-based claims for hallucination belong in insanity phase; not at guilt phase
Proper scope of 28(a) admissibility alongside Wells/Wetmore lineage	Diminished actuality evidence remains admissible at guilt phase	Remnant of diminished capacity should be rejected; 28(a) permits factual defense only	28(a) allows evidence of mental disorder to show lack of specific intent/malice only if not insanity; insanity analysis reserved for sanity phase

People v. Beltran, 56 Cal.4th 935 (Cal. 2013) (defines heat of passion and unreasonable self-defense framework)
People v. Rios, 23 Cal.4th 450 (Cal. 2000) (imperfect self-defense negates malice when belief is unreasonable)
In re Christian S., 7 Cal.4th 768 (Cal. 1994) (distinguishes unreasonable self-defense from diminished capacity)
People v. Flannel, 25 Cal.3d 668 (Cal. 1979) (developed imperfect self-defense doctrine)
People v. Anderson, 28 Cal.4th 767 (Cal. 2002) (connects self-defense belief to lack of malice; imperfect self-defense)
Mejia-Lenares, 135 Cal.App.4th 1437 (Cal. App. 2006) (delusions may be treated under diminished capacity; limits on self-defense theory)
Wells, 33 Cal.2d 330 (Cal. 1969) (diminished capacity doctrine and bifurcated trial framework)
Wetmore, 22 Cal.3d 318 (Cal. 1978) (duality of evidence duplication for diminished capacity and insanity)
M’Naghten’s Case, 8 Eng. Rep. 718 (Eng. 1843) (establishes M’Naghten insanity standard)
Clark v. Arizona, 548 U.S. 735 (U.S. 2006) (due process regarding defense evidence and insanity)