## Facts

- Mattie M. Evans was convicted of second-degree murder for fatally stabbing a man on a Washington, D.C. sidewalk around 5:30 a.m. on May 1, 1955.
- The government presented three disinterested eyewitnesses; none saw the entire incident, but their combined testimony described a brief encounter followed by tussling and fighting during which Evans inflicted mortal knife wounds.
- Evidence indicated the decedent was intoxicated; the government offered no clear motive, and there was no indication of robbery or prior relationship.
- Evans testified she was returning home alone when the decedent approached from behind, made sexual propositions and obscene remarks, grabbed her, and tore her clothing; she stabbed him during the struggle with a knife she carried for protection.
- To support her claim that the decedent was the aggressor, Evans sought to call the decedent’s wife to testify that he became belligerent and aggressive when drinking and could become psychotic-like.
- The trial court excluded the wife’s testimony, and the jury returned a guilty verdict.

## Issues

1. Whether, when self-defense is claimed and the identity of the aggressor is genuinely disputed, evidence of the deceased’s violent or belligerent disposition while intoxicated is admissible to show the deceased was the probable aggressor even if the defendant lacked prior knowledge of that disposition.
2. Whether excluding the decedent’s wife’s proffered testimony was prejudicial error requiring reversal.

## Decision

- The court of appeals reversed the conviction and remanded for a new trial.
- The court held the excluded testimony about the decedent’s belligerence while intoxicated should have been admitted to corroborate Evans’s account that the decedent initiated the violence.
- The exclusion was not harmless because the aggressor question was central, eyewitness accounts were incomplete, and the prosecution offered no apparent motive.

## Legal Principles

- In a homicide case with a self-defense claim, evidence of the deceased’s violent or belligerent character may be admissible to help determine who was the aggressor when that issue is materially disputed.
- Character evidence of the deceased, even if unknown to the defendant at the time, can be admitted to corroborate the defendant’s version that the deceased was the aggressor (as distinct from proving the defendant’s state of mind or the reasonableness of fear).
- Erroneous exclusion of such corroborative evidence warrants reversal when it could have affected the jury’s resolution of the aggressor question.

## Conclusion

The court ordered a new trial because the jury should have been allowed to hear testimony that the decedent tended to become belligerent when intoxicated, which was relevant to whether he likely initiated the encounter underlying Evans’s self-defense claim.


Evans v. United States, 277 F.2d 354 (D.C. Cir. 1960)