People v. Washington, 2012 IL 110283

Defendant Malvin Washington was convicted of two counts of first-degree murder and one count of aggravated battery with a firearm after trial in Cook County.
The jury was instructed on justifiable use of force (self-defense) but not on second-degree murder or involuntary manslaughter.
The appellate court reversed, holding that when evidence supports a self-defense instruction, a mandatory second-degree murder instruction must be given.
Evidence showed a confrontation at an accident scene where Washington allegedly shot Ronald Lee and others testified about the events surrounding the shooting.
Washington claimed self-defense, asserting he reasonably believed deadly force was necessary; the State argued against a mandatory second-degree instruction.
The Supreme Court of Illinois affirmed the appellate court, holding that when self-defense is instructed, a mandatory second-degree murder instruction must be given, and the failure to do so requires remand for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a second-degree murder instruction be given with a self-defense instruction?	People argued Lockett requires the mandatory pairing.	Washington argued Lockett should not be mandatory in all cases.	Yes; second-degree instruction mandatory when self-defense is instructed.
Is the instructional error harmless or structural when second-degree instruction is omitted after self-defense given?	People contends error may be reversible but not structural.	Washington asserts potential impact on verdict and merits reversal.	Not automatic structural error; reversal affirmed due to the instructional omission.
Did the failure to instruct on second-degree murder affect the trial outcome given conflicting evidence on self-defense?	People argues conflict warranted dual instructions.	Washington claims evidence could still support self-defense without the second-degree instruction.	Yes; the outcome could have differed without the instruction.

People v. Lockett, 82 Ill. 2d 546 (Ill. 1980) (mandatory second-degree/self-defense pairing when evidence supports self-defense)
People v. O’Neal, 104 Ill. 2d 399 (Ill. 1984) (self-defense instruction and accompanying mitigating evidence)
People v. Jeffries, 164 Ill. 2d 104 (Ill. 1995) (burdens and interplay of self-defense and second-degree murder instructions)
People v. Edmondson, 328 Ill. App. 3d 661 (Ill. App. Ct. 2002) (self-defense instruction paired with second-degree/manslaughter instruction analysis)
People v. Russell, 215 Ill. App. 3d 8 (Ill. App. Ct. 1991) (Lockett framework applied to dual instructions)