STATE v. RONALD M. SINGLETON, SC 17795
Judicial District of New Haven
Criminal; Self-Defense; Whether Trial Court's Jury Instructions Regarding Defendant's Claim of Self-Defense were Improper in that they Removed from the Jury's Consideration the Disputed Factual Issue of Whether he used Deadly or Nondeadly Physical Force. The defendant was charged with murder in connection with the stabbing death of Leonard Cobbs. At trial, he raised the affirmative defense of self-defense. He testified that Cobbs initiated a fight with him during which Cobbs grabbed a knife, and that after he took hold of Cobbs' wrists, the knife penetrated Cobbs' body during the ensuing struggle. The trial court repeatedly stated in its jury instructions on self-defense that the defendant had used deadly physical force upon Cobbs. It did not give any instructions regarding the use of nondeadly physical force, nor did it instruct the jury that it was required to decide what degree of force the defendant had used. The jury ultimately found the defendant guilty of the lesser included offense of manslaughter in the first degree. The defendant appealed, claiming that the court's self-defense instructions were improper in that they removed from the jury's consideration the disputed factual issue of whether he used deadly or nondeadly physical force. The Appellate Court agreed (97 Conn. App. 679) and reversed the conviction. In doing so, it first noted that it is much easier for the state to satisfy its burden of disproving a claim of self-defense beyond a reasonable doubt when deadly physical force has been used. It then decided that the defendant's testimony did not warrant a conclusion that his actions constituted deadly physical force as a matter of law and that the defendant was therefore entitled to have the jury resolve the factual issue of whether he used deadly or nondeadly physical force. Accordingly, it held that the trial court's instructions were improper because they had the effect of prohibiting the jury from considering whether the defendant had, in fact, used nondeadly force. It further determined that the improper instructions were not harmless beyond a reasonable doubt because the jury could have concluded on the basis of the evidence presented that the defendant's use of physical force was reasonable under a theory of nondeadly self-defense. In this appeal, the Supreme Court will determine whether the Appellate Court's conclusions were correct.