Wilson v. State, 30 A.3d 955

Petitioner Antajuan Lawntee Wilson was convicted of first-degree murder and related offenses in Howard County.
Appeal challenged the circuit court’s refusal to instruct on imperfect self-defense and the rule of provocation.
Prior appellate rulings (Court of Special Appeals) affirmed the convictions and rejected the arguments.
The Court granted certiorari to review two questions: the some-evidence standard and mitigation defenses.
The Court held the some-evidence standard was misapplied and Petitioner was entitled to an imperfect self-defense instruction, but rejected hot-blooded rage as a basis for a provocation defense.
Consequently, the judgment of the Court of Special Appeals is vacated and the case is remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the some-evidence standard was misapplied	Wilson argued the standard was improperly modified by lower courts.	State maintained the existing standard control.	Yes; the some-evidence standard was misapplied, requiring reversal.
Whether imperfect self-defense and hot-blooded provocation should have been instructed	Wilson contends the jurors should receive imperfect self-defense and provocation instructions.	State argues no entitlement to those mitigations based on record.	Imperfect self-defense instruction required; hot-blooded provocation instruction rejected.

Faulkner, 301 Md. 482 (Md. 1984) (imperfect self-defense mitigates murder to voluntary manslaughter)
Dykes v. State, 319 Md. 206 (Md. 1990) (some evidence triggers instruction on self-defense; burden shifts to State)
Simmons v. State, 313 Md. 33 (Md. 1988) (some evidence standard requires jury instruction if evidence supports it)
Cunningham v. State, 58 Md. App. 249 (Md. 1984) (articulates standards for self-defense jury instructions)