## Facts

- Evelyn Humphrey shot and killed her partner, Albert Hampton, in their Fresno home and told responding police she shot him because she “couldn’t take him beating on [her]” anymore.
- Evidence showed a history of domestic violence, including Hampton’s prior threats to kill Humphrey and an incident the night before the killing in which he struck her while intoxicated and fired a gun, sending a bullet through a bedroom window.
- Humphrey was charged with murder with a personal-use firearm allegation and asserted self-defense.
- The defense presented expert testimony under Evidence Code § 1107 that Humphrey suffered from an extreme case of battered women’s syndrome (BWS) and that prolonged battering can affect how a victim perceives danger and available options.
- The trial court instructed jurors they could consider BWS evidence only in deciding whether Humphrey actually believed deadly force was necessary, not in deciding whether that belief was reasonable.
- The jury convicted Humphrey of voluntary manslaughter with personal use of a firearm; the Court of Appeal affirmed the conviction (with a remand related to sentencing on the enhancement).

## Issues

1. Whether expert testimony on battered women’s syndrome under Evidence Code § 1107 is admissible only to assess the defendant’s actual (subjective) belief in the need for self-defense, or also to assess the reasonableness (objective) of that belief.
2. Whether it was reversible error to instruct the jury that BWS evidence could not be considered on the reasonableness element of self-defense.

## Decision

- The Supreme Court of California reversed.
- The court held that BWS evidence is relevant to both whether the defendant actually believed deadly force was necessary and whether that belief was objectively reasonable.
- The trial court’s limiting instruction was erroneous because it improperly prevented jurors from considering BWS evidence when evaluating the reasonableness component of self-defense.
- The error was prejudicial because the evidence supported a plausible claim of perfect self-defense, and the restricted instruction could have affected the verdict.

## Legal Principles

- California self-defense requires both an actual belief in imminent danger and necessity of deadly force and a belief that is objectively reasonable.
- The “reasonable person” standard is objective but depends on the defendant’s situation and the facts known to the defendant at the time; it is not assessed in the abstract.
- Evidence Code § 1107 permits expert BWS testimony when relevant (and subject to Evidence Code § 352), and it is not confined to any single purpose in a self-defense case.
- BWS evidence may assist jurors in evaluating the reasonableness of a defendant’s perception of imminent danger and the perceived availability of alternatives, and it may bear on credibility when the defendant testifies.
- Prior authority limiting BWS evidence to the subjective component of self-defense was disapproved to the extent it imposed that restriction.

## Conclusion

The California Supreme Court held that battered women’s syndrome testimony may be considered on both the subjective and objective elements of self-defense, and that an instruction limiting such evidence to the defendant’s actual belief alone was prejudicial error requiring reversal.


People v. Humphrey, 13 Cal. 4th 1073 (Cal. 1996)