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People v. Beardslee, 53 Cal.3d 68, 53 Cal.3d 1179A, 806 P.2d 1311, 279 Cal.Rptr. 276

Facts

Defendant Beardslee was charged with the first-degree murders of Paula Geddling and Stacy Benjamin, both of whom were killed on April 25, 1981. Beardslee, along with accomplices, planned to confront the victims over a drug deal gone wrong. After a series of violent events, both victims were murdered, with Beardslee actively participating in the killings. He later confessed to the police, providing details of the murders and his involvement.

Defendant Donald Jay Beardslee was charged under the 1978 death penalty law with the first degree murders of Paula (Patty) Geddling and Stacy Benjamin under two special circumstances. A jury found defendant guilty of committing both murders with premeditation and deliberation (Pen.Code, §§ 187, 189; all section references are to that code unless otherwise indicated) and further determined that each murder was committed under two special circumstances: concurrent conviction of multiple murders (§ 190.2, subd. (a)(3)) and intentional killing for the purpose of preventing the victim from testifying as a witness to a separate crime (§ 190.2, subd. (a)(10)).

Issue

Did the trial court err in refusing to instruct the jury on the defense that the defendant did not intend to kill the victims because he honestly but mistakenly believed they were dead when he inflicted the fatal blows?

Defendant relied on the defense that he participated in the homicides because he feared that if he did not do so, Rutherford would kill him or have him killed.

Rule

A person is not guilty of a crime if he acts under threats or menaces that cause him reasonably to fear that his life would be in immediate danger if he did not commit the otherwise criminal act. However, such threats are not a defense in cases of first-degree murder with special circumstances.

A person is not guilty of a crime if he acts under threats or menaces that cause him reasonably to fear that his life would be in immediate danger if he did not do the otherwise criminal act.

Analysis

The court found that the jury was adequately instructed to consider the defendant's honest belief regarding his life being in danger and its effect on his mental state. The court concluded that any error in refusing to give the requested instruction was harmless, as the jury had already been instructed to consider the defendant's mental state in relation to the specific intent required for first-degree murder.

Notwithstanding these instructions, defendant claims the trial court erred in refusing his request for an instruction that threats causing him to believe honestly that 'his own life was in imminent peril' would negate malice aforethought and reduce his crime to voluntary manslaughter.

Conclusion

The court set aside one of the special circumstances but affirmed the judgment of guilt for first-degree murder. The court held that the defendant's participation in the murders was sufficient to uphold the convictions.

We conclude that one of the multiple-murder and both witness-killing special circumstances must be set aside, and that the judgment otherwise be affirmed.

Who won?

The People (State of California) prevailed in the case as the court affirmed the convictions and the death sentence, finding sufficient evidence to support the jury's verdict.

Defendant, age 37, was then living in his studio apartment in Redwood City with Ricki Soria, whom he had met two months earlier while she was hitchhiking.

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