People v. Mills
55 Cal. 4th 663
| Cal. | 2012Background
- Defendant Mills was charged with murder and pled not guilty and not guilty by reason of insanity.
- Guilt phase included a special instruction that the defendant was conclusively presumed sane at the time of the offense.
- Defense objected, arguing the presumption could mislead the jury and sought a definition of insanity instruction.
- Jury convicted Mills of first-degree murder; sanity was later found, in a separate sanity trial, to be sane at the time of the offense.
- Sentenced to 50 years to life; Mills appealed, challenging the guilt-phase presumption instruction as improper under state law.
- California Supreme Court held the instruction was erroneous under state law but harmless given the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the guilt-phase presumption of sanity permissible under due process? | Mills argued the presumption shifted burdens and risked disregard of mental illness evidence. | Mills contended the instruction confused the jury and violated due process by lowering the burden. | No due process violation; but the instruction was erroneous under state law. |
| Did the presumption of sanity have any relevance to guilt-phase issues? | Presumption misled the jury about mental state evidence at guilt. | Sanity was irrelevant to guilt; evidence should be considered only in insanity phase. | Instruction improper because sanity is irrelevant at guilt phase; however harmless here. |
| Was the error prejudicial under state-law standards (Watson test)? | Instruction likely confused jury and affected verdict. | Record shows substantial evidence supporting guilt irrespective of the instruction. | Harmless beyond a reasonable doubt under Watson. |
| How does the rifle of case law (Wells, Coddington, Patterson, Blacksher, Clark) apply to this instruction? | Ninth Circuit decisions support due-process concerns over presumption of sanity. | Clark limits the reach, distinguishing Arizona's framework from California's bifurcated scheme. | California law permits bifurcation; the instruction here is misapplied but not due process-violative. |
| What is the proper role of evidence of mental illness at guilt vs. sanity phases? | Mental illness evidence is relevant to form of malice or intent at guilt phase. | Mental illness evidence belongs to sanity/insanity considerations, not guilt. | Current law allows mental state evidence at guilt only for specific intent; sanity evidence belongs in insanity phase. |
Key Cases Cited
- People v. Troche, 206 Cal. 35 (Cal. 1928) (established bifurcated trial principles under § 1026)
- People v. Wells, 33 Cal.2d 330 (Cal. 1949) (limited admissibility of mental state evidence and discussed presumption frameworks)
- Coddington, 23 Cal.4th 529 (Cal. 2000) (presumption of sanity instruction discussion in death penalty context)
- Patterson v. Gomez, 223 F.3d 959 (9th Cir. 2000) (due process concerns with presumption of sanity in guilt phase)
- Stark v. Hickman, 455 F.3d 1070 (9th Cir. 2006) (presumption of sanity instruction reviewed in federal context)
- Blacksher, 52 Cal.4th 769 (Cal. 2011) (summarily rejected due-process challenge to presumption instruction)
- Clark v. Arizona, 548 U.S. 735 (U.S. 2006) (limits on presumption-based restrictions on mental-state evidence in Arizona)
- Mejia-Lenares, 135 Cal.App.4th 1437 (Cal. App. 2006) (distinguishing diminished actuality from imperfect self-defense)
- Middleton v. McNeil, 541 U.S. 433 (U.S. 2004) (framework for evaluating ambiguous jury instructions under due process)