People v. McDonald
2016 IL 118882
| Ill. | 2017Background
- In May 2004 Stanley McDonald stabbed his boyfriend, Lawrence Gladney; Gladney later died from complications after surgery for a carotid injury. McDonald was convicted of first-degree murder after a 2012 retrial and sentenced to 27 years.
- Evidence: three stab wounds (one deep facial wound that involved the carotid), prior incident in which McDonald had cut Gladney, witness testimony that McDonald had been carrying a knife earlier that day and threatened to kill Gladney, and equivocal testimony about whether Gladney struck McDonald during a struggle over a bicycle.
- Trial court instructed the jury on self-defense and on second-degree murder based on unreasonable belief in self-defense, but refused instructions on involuntary manslaughter and second-degree murder based on serious provocation (mutual combat).
- Appellate court affirmed, concluding the trial court did not abuse its discretion in refusing the tendered instructions and that a rebuttal testimony error was harmless. The Illinois Supreme Court granted review.
- The Supreme Court considered (1) the proper quantum of evidence required to justify giving a lesser‑included or mitigating-offense instruction and (2) the appropriate standard of appellate review for a trial court’s refusal to give such instructions. The court affirmed McDonald’s conviction.
Issues
| Issue | People’s Argument | McDonald’s Argument | Held |
|---|---|---|---|
| Standard for entitlement to lesser‑included/affirmative‑defense jury instruction | Trial court should deny when evidence insufficient; deference appropriate | Defendant: instruction required where there is some evidence; reviewing court should apply de novo review | A defendant is entitled to a lesser instruction if there is some evidence that, if believed by the jury, reduces the offense; but appellate review of a trial court’s refusal is for abuse of discretion |
| Quantum phrasing: "credible evidence" vs "some evidence" | State implicitly defended higher "credible evidence" formulations | McDonald urged that the court use a low threshold—some evidence—without credibility weighing | Court rejected "credible evidence" language and adopted the "some evidence" standard: any evidence that, if believed, would reduce the offense |
| Whether trial court erred in refusing involuntary manslaughter instruction (recklessness theory) | Trial court: evidence showed intentional conduct (multiple wounds, prior stabbing, threats); refusal proper | McDonald: evidence (similar size, two superficial wounds, intoxication, post‑stab pleas for help) supported involuntary manslaughter | Trial court did not abuse its discretion; evidence did not provide sufficient proof of mere recklessness |
| Whether trial court erred in refusing second‑degree murder (serious provocation / mutual combat) instruction | State: no mutual combat or proportionate provocation; defendant instigated and was armed | McDonald: mutual combat evidence (struggle over bike, possible blows, injuries to both) warranted instruction | Trial court did not abuse its discretion; evidence of serious provocation / mutual combat was insufficient |
Key Cases Cited
- People v. Lockett, 82 Ill. 2d 546 (Ill. 1980) (when evidence supports self‑defense instruction, jury also must be permitted to consider unreasonable‑belief second‑degree murder)
- People v. Everette, 141 Ill. 2d 147 (Ill. 1990) (a homicide defendant is entitled to an instruction on self‑defense if some evidence supports it)
- People v. Washington, 2012 IL 110283 (Ill. 2012) (addressed interplay between self‑defense and mandatory second‑degree murder instruction as a counterpart)
- People v. DiVincenzo, 183 Ill. 2d 239 (Ill. 1998) (distinguishes murder and involuntary manslaughter by defendant’s mental state and lists factors relevant to manslaughter instruction)
- People v. Jones, 219 Ill. 2d 1 (Ill. 2006) (discusses instruction standards and prior formulations such as "credible evidence")
- People v. Whiters, 146 Ill. 2d 437 (Ill. 1992) (reversed trial court for refusing involuntary manslaughter instruction where record contained evidence of recklessness)