## Facts

- In 2005 at an Emeryville Amtrak station, Ahkin Ramond Mills confronted Jason Jackson-Andrade, taunted him about having a gun, and escalated the encounter inside the station.
- Mills stated that if the victim lacked a gun, Mills had one, then shot the victim multiple times as the victim attempted to move away; the victim died at the scene.
- Mills was charged with first-degree murder and firearm enhancements and entered pleas of not guilty and not guilty by reason of insanity (NGRI), triggering bifurcated guilt and sanity phases.
- At the guilt phase, Mills did not dispute the shooting but argued imperfect self-defense based on mental illness, claiming an honest (though unreasonable) belief in imminent danger.
- Defense evidence included testimony that Mills had paranoid and delusional beliefs and expert testimony diagnosing a delusional disorder that could cause misinterpretation of benign events as threats.
- Over defense objection, the trial court instructed the guilt-phase jury that Mills was “conclusively presumed” sane at the time of the offense and refused a defense request to instruct on the legal definition of sanity.
- The jury convicted Mills of first-degree murder and found the firearm enhancement true; at the separate sanity phase, the jury found Mills sane; Mills was sentenced to 50 years to life.

## Issues

1. Whether instructing the guilt-phase jury that the defendant is “conclusively presumed” sane violates federal due process by effectively reducing the prosecution’s burden to prove the mental elements of murder beyond a reasonable doubt.
2. Whether, in a bifurcated trial under Penal Code section 1026, it is state-law error to instruct the guilt-phase jury on sanity or a presumption of sanity.
3. If the instruction was erroneous, whether the error was prejudicial.

## Decision

- The California Supreme Court affirmed the judgment.
- The court held there was no federal due process violation because the presumption-of-sanity instruction concerned sanity (a separate question from mens rea) and did not direct the jury to presume intent, malice, deliberation, or premeditation.
- The court held the guilt-phase instruction was erroneous under California law because sanity is irrelevant at the guilt phase in bifurcated NGRI proceedings and no instruction on sanity should be given then.
- The court found the state-law instructional error harmless in light of the complete charge to the jury and the evidence supporting first-degree murder.

## Legal Principles

- In bifurcated proceedings under Penal Code section 1026, sanity is reserved for the sanity phase and is irrelevant to the guilt phase; the guilt-phase jury should not be instructed on sanity or a presumption of sanity.
- The prosecution must prove beyond a reasonable doubt all elements of the charged offense, including any required mental state; a sanity presumption does not substitute for proof of mens rea.
- Mental-illness evidence may be considered at the guilt phase to the extent it is relevant to required mental states and to defenses such as imperfect self-defense, but it may not be offered to prove legal insanity at that phase.
- An erroneous guilt-phase reference to sanity does not require reversal where the instructions as a whole preserve the prosecution’s burden on the elements and there is no reasonable probability of a more favorable result absent the error.

## Conclusion

The court upheld Mills’s first-degree murder conviction, concluding that a guilt-phase instruction referencing a conclusive presumption of sanity was improper under state bifurcation rules but did not violate due process and was harmless because the jury remained properly instructed on the prosecution’s burden and the record strongly supported the verdict.


People v. Mills, 55 Cal. 4th 663, 147 Cal. Rptr. 3d 833 (2012)