State v. Headley, 210 W. Va. 524

Summary

The Supreme Court of Appeals of West Virginia reversed Frances Martha Headley's involuntary manslaughter conviction arising from the stabbing death of Brian M. Evans. The court held that Headley presented sufficient evidence of self-defense, that the State failed to prove beyond a reasonable doubt that she did not act in self-defense, and that she was entitled to a judgment of acquittal. The court also discussed the trial court's obligation to instruct the jury on a supported theory of self-defense.

Holdings

1. Once Headley presented sufficient evidence to create a reasonable doubt that the killing resulted from self-defense, the State was required to prove beyond a reasonable doubt that she did not act in self-defense. The State failed to meet that burden, and Headley was entitled to acquittal.
2. When competent evidence tends in any appreciable degree to support a defendant's theory of self-defense, the trial court must permit the defendant to present that theory and give a correct instruction on it when requested, even if the evidence is slight.

Questions Presented

1. Whether the evidence was sufficient to prove beyond a reasonable doubt that Headley did not act in self-defense when she used deadly force against Evans.
2. Whether Headley was entitled to present evidence and receive jury instructions supporting her theory of self-defense when competent evidence supported that theory.

Disposition

vacated