AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Late on May 21, 2016, Defendant Francisco Campos stabbed Ruben Moreno (Victim) with a large kitchen knife during a conflict that arose at a motel where both the Victim and Defendant resided. The conflict initially involved Defendant and Jose Franco, Defendant's former boss, over unpaid wages. The disagreement escalated to a physical altercation, during which the circumstances of how Defendant came to possess the knife and whether the stabbing was intentional or accidental were disputed. Defendant claimed the stabbing was accidental, occurring as Victim tried to defuse the situation, while witnesses for the State testified that Defendant approached and stabbed the Victim without warning (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by not instructing the jury on involuntary manslaughter as a lesser included offense and contended that there was insufficient evidence to support the conviction for second-degree murder (para 1).
• Plaintiff-Appellee: Contended that there was no error in the jury instructions and that sufficient evidence supported the Defendant's conviction for second-degree murder (paras 7, 14).

Legal Issues

• Whether the district court erred in denying the Defendant's request for an involuntary manslaughter jury instruction.
• Whether there was sufficient evidence to support the jury’s conviction for second-degree murder.

Disposition

• The court reversed the conviction for second-degree murder and remanded for a new trial, concluding that the district court erred in failing to give the requested involuntary manslaughter instruction (para 1).

Reasons

• The court, per Judge Jennifer L. Attrep, with Judges Megan P. Duffy and Briana H. Zamora concurring, found that the district court erred in not instructing the jury on involuntary manslaughter. The decision was based on the principle that a defendant is entitled to jury instructions on a lesser included offense when evidence supports the defendant's theory of the case. The court determined that there was sufficient evidence presented at trial to support a finding of criminal negligence, which could have led to a conviction for involuntary manslaughter. This conclusion was drawn from the evidence, particularly Defendant's statements during a police interview, which suggested that the stabbing could have been unintentional and occurred in a context that might not have amounted to second-degree murder but rather to involuntary manslaughter due to criminal negligence. The court distinguished this case from precedent by emphasizing the specific circumstances under which Defendant came to possess the knife and the subsequent actions leading to the Victim's stabbing. Despite reversing the conviction for second-degree murder, the court also concluded that there was sufficient evidence to support the conviction should the jury have chosen to convict on that charge, thus allowing for a retrial without violating double jeopardy principles (paras 5-17).