State v. Lambdin
2017 UT 46
| Utah | 2017Background
- Dennis Lambdin stabbed and bludgeoned his wife to death after ongoing marital disputes, then admitted the killing and made statements indicating anger and premeditation.
- Lambdin sought reduction of murder to manslaughter under Utah’s special mitigation statute for extreme emotional distress (Utah Code § 76-5-205.5), asserting extreme emotional distress as mitigation.
- At trial the court gave jury instructions informed by this court’s prior definition of extreme emotional distress; Lambdin objected to parts of those instructions as legally erroneous.
- The jury unanimously convicted Lambdin of murder, finding he failed to prove special mitigation by a preponderance of the evidence; the court of appeals affirmed.
- The Utah Supreme Court granted certiorari to decide (1) whether Bishop’s definition of extreme emotional distress remains controlling, (2) whether that definition requires the defendant’s loss of self-control to be reasonable from an objective standard, and (3) whether the jury instructions were legally sufficient.
Issues
| Issue | Lambdin's Argument | State's Argument | Held |
|---|---|---|---|
| Whether this court may adopt/maintain a judicial definition of “extreme emotional distress” beyond statutory text | Bishop’s definition was dicta and unnecessary; statute’s plain language suffices; no additional judicial definition required | Court may interpret statute and Bishop’s formulation is authoritative and consistent with statutory purpose | Bishop’s definition is valid and remains controlling |
| Whether the Bishop framework requires that the defendant’s loss of self-control be objectively reasonable | Loss of self-control need only be shown subjectively as part of the emotional reaction; objective reasonableness is not required | Loss of self-control must be measured objectively: the average reasonable person under the then-existing circumstances must have been overwhelmed | Court holds defendant must prove the loss of self-control was reasonable from a reasonable-person standpoint |
| Whether requiring objective reasonableness improperly adds an element or alters statutory text | Imposes an extra substantive element not in statute; courts cannot create crimes or defenses | Interpretation effectuates legislative intent and statutory plain meaning; it does not add a new criminal element | Requiring an objective reasonable explanation/excuse for the extreme emotional distress is an interpretation of the statute, not an impermissible addition |
| Whether the trial court’s jury instructions were legally insufficient or misleading such that a new trial is required | Certain instructions (esp. Instruction 19) were ambiguous and could lead jurors to think the killing itself had to be reasonable; ambiguity was not cured | Instructions, read as a whole (including Instruction 21 and counsel’s closing), correctly instructed jury that reasonableness applies to loss of self-control, not the killing | Instructions were legally sufficient when read together; no reversible ambiguity or prejudice shown |
Key Cases Cited
- State v. Bishop, 753 P.2d 439 (Utah 1988) (court’s prior definition of extreme emotional disturbance/distress)
- State v. White, 251 P.3d 820 (Utah 2011) (applied Bishop and described reasonable-person formulation)
- State v. Maestas, 299 P.3d 892 (Utah 2012) (standard that jury instructions taken as a whole must fairly instruct the law)
- Marbury v. Madison, 5 U.S. (1 Cranch) 137 (U.S. 1803) (judicial duty to interpret statute and declare what the law is)