People v. Humphrey
921 P.2d 1 (Ca. 1996)

Facts:

  • During the evening of March 28, 1992, Evelyn Humphrey shot and killed Albert Hampton in their Fresno home.
    • She was in a very abusive relationship with Albert, who would often get drunk, swear at her, threaten her, and beat her.
  • The day before the shooting, Albert hit her and later shot at her.
  • The day of the shooting, he started hitting her again, and Evelyn picked up the gun sitting on the kitchen counter before he could get to it. She testified that he reached to grab her hand, so she shot him.
  • When the police arrived, Evelyn was very open and admitted to it, stating that she couldn’t take him beating her anymore, and she warned him.
  • She was charged with murder, and argued self-defense.

History:
The jury found her guilty of voluntary manslaughter with personal use of a firearm.

  • The court instructed that Battered Women’s Syndrome was relevant only for the purpose of determining the subject honest belief component of self-defense.

Issue:
Whether Battered Women’s Syndrome is relevant to show not only subjective, honest belief, but also to show objective reasonableness.

Holding:
Yes. Case reversed.

Reasoning:

  • Battered woman’s syndrome has been defined as a series of common characteristics that appear in women who are abused physically and psychologically over an extended period of time by the dominant male figure in their lives.
    • They often feel they are responsible for the abusive relationship and become dependent on the abuser.
    • Many battered women remain in the relationship because of lack of money, social isolation, lack of self-confidence, inadequate police response, and a fear (often justified) of reprisals by the batterer.
    • The victim has seen the cycle so many times that she becomes aware and can predict when violence is coming.
  • Here, Dr. Bowker, an expert, testified that Evelyn suffered from battered woman’s syndrome in “about as extreme a pattern as you could find.”
    • In addition, she was the child of an alcoholic, as wells an incest victim.
  • “In assessing reasonableness, the question is whether a reasonable person in the defendant’s circumstances would have perceived a threat of imminent injury or death, and not whether killing the abuser was reasonable in the sense of being an understandable response to ongoing abuse.”
    • “As violence increases over time, and threats gain credibility, a battered person might become sensitized and thus able reasonably to discern when danger is real and when it is not…The battered woman is particularly able to predict accurately the likely extent of violence in any attack on her. That conclusion could significantly affect the jury’s evaluation of the reasonableness of defendant’s fear for her life.”

Rule: Expert testimony that a defendant is suffering from battered women’s syndrome is generally admissible in a murder prosecution not only on the question of whether the defendant actually believed that it was necessary to kill in self-defense, but on question of reasonableness of that belief.