## Facts

- Around 1989, Pedro Aguilar Benitez immigrated from Mexico to the United States and entered a common-law marriage with Sandra Castrejon.
- Benitez was abusive toward Castrejon and intensely jealous, including a belief that Castrejon was romantically involved with Benitez’s 19-year-old son.
- On the morning of August 20, 2000, before leaving for work, Castrejon told Benitez the relationship was over and instructed him to leave the family home.
- When Castrejon returned from work, Benitez was still at the home and begged her to take him back; she refused.
- Castrejon then went to stay with her sister for several hours.
- When Castrejon returned later that day, Benitez was still at the home, and the two argued.
- During the argument, Benitez told Castrejon that he did not want anyone else to have her, retrieved a knife from the kitchen, and stabbed her to death.
- In multiple police interviews after the killing, Benitez made statements that the prosecution treated as showing the killing was premeditated.
- Benitez was charged with Castrejon’s death and tried for murder.
- At trial, Benitez sought to call a psychologist to testify that Benitez’s thinking and response to jealousy, as a Mexican man, differed from that of an Anglo-American man, in order to support a heat-of-passion voluntary manslaughter theory.
- The trial court excluded the psychologist’s testimony on the ground that California law does not recognize a culture-specific “reasonable provocation” standard.
- The jury convicted Benitez of first-degree murder, and Benitez appealed, arguing that exclusion of the psychologist’s testimony denied him due process and a fair trial.

## Issues

1. Did the trial court err by excluding defense psychologist testimony offered to support a culture-based theory of “reasonable provocation” for heat-of-passion voluntary manslaughter?
2. Did exclusion of that testimony violate Benitez’s constitutional rights to due process and a fair trial by preventing him from presenting a complete defense?

## Decision

- The Court of Appeal affirmed the judgment of conviction for first-degree murder.
- The court held the trial court properly excluded the psychologist’s testimony to the extent it was offered to justify a different “reasonable provocation” benchmark based on the defendant’s culture.
- The court rejected Benitez’s constitutional claims, concluding that excluding evidence that would have invited the jury to apply an improper legal standard did not deny due process or a fair trial.

## Legal Principles

- Heat-of-passion voluntary manslaughter requires evidence of provocation and a killing in the heat of passion, and the provocation element includes an objective component measured by an ordinary reasonable person standard.
- A defendant may present evidence bearing on the defendant’s subjective mental and emotional state, but the jury may not be instructed (or invited through testimony) to replace the objective reasonable-person test with a culture-specific variant.
- Trial courts may exclude testimony that would misstate the governing legal test or would be offered primarily to argue an incorrect rule of law to the jury.
- The right to present a defense does not require admission of evidence that is legally irrelevant because it depends on a standard the law does not recognize.

## Conclusion

People v. Benitez upheld a first-degree murder conviction where the defendant sought to introduce psychologist testimony suggesting that cultural background changed what should count as reasonable provocation for heat-of-passion manslaughter; the court concluded California’s provocation inquiry retains an objective ordinary-reasonable-person component that may not be replaced with a culture-based standard, and exclusion of the proffered testimony did not violate due process or fair-trial rights.


People v. Benitez, 2002 WL 31009371 (2002)