Commonwealth v. Chambers

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After a jury trial, Defendant was convicted of involuntary manslaughter. At trial, Defendant contended that he stabbed the victim to death in self-defense. The evidence indicated that the victim was the first to provoke a nondeadly altercation with Defendant, but a dispute arose as to whether Defendant or the victim was the first to grab the knife that escalated the conflict into a deadly dispute. Defendant appealed, arguing that the trial judge erred by excluding evidence that the victim had participated in a violent assault of a third person less than two years after the incident resulting in the victim's death. The Supreme Court vacated the conviction, holding (1) a judge may admit "adjutant evidence" where there is a dispute as to who initiated a threat or use of deadly force; (2) the judge here erred in concluding that adjutant evidence was admissible only where there was a dispute as to who threatened or struck the first blow; and (3) this mistake resulted in prejudice to Defendant. Remanded for a new trial. View "Commonwealth v. Chambers" on Justia Law