## Facts

- Prosenjit Poddar, a UC Berkeley graduate student from India, developed an obsessive attachment to Tatiana Tarasoff after meeting her in a dance class and interpreting their contact as a serious relationship.
- After Tarasoff rejected an intimate relationship, Poddar’s functioning deteriorated; he exhibited depression, disorganized behavior, and stated to others that he might kill her.
- He received psychiatric evaluation and treatment; a campus psychologist reported he was dangerous and suffering from paranoid schizophrenia, and police briefly detained then released him.
- On the day of the killing, Poddar returned to Tarasoff’s home armed with a pellet gun and a knife; after she screamed and fled, he shot her and repeatedly stabbed her.
- Poddar then called police, reported the stabbing, and requested to be handcuffed.
- At trial, experts sharply disagreed on whether Poddar had paranoid schizophrenia and diminished capacity affecting his ability to form the mental state for murder.
- The defense sought anthropological testimony linking cultural dislocation and cross-cultural misunderstanding to Poddar’s mental state; the court limited the anthropologist to descriptive background and barred a direct opinion on diminished capacity.
- The court excluded certain lay observations of Poddar’s post-homicide behavior offered to support abnormal mental condition.
- The jury convicted Poddar of second-degree murder and found him sane; on appeal, he challenged the murder conviction based on instructional and evidentiary errors bearing on mental state and degree of homicide.

## Issues

1. Whether the trial court erred by failing to instruct, on its own motion, on unconsciousness as a complete defense in light of mental-health evidence.
2. Whether the jury instructions adequately explained how diminished capacity could negate malice or premeditation and reduce murder to manslaughter.
3. Whether limiting anthropological testimony about cultural stress improperly restricted evidence relevant to diminished capacity.
4. Whether exclusion of lay testimony regarding post-homicide behavior improperly restricted circumstantial evidence of abnormal mental condition.
5. Whether the combined instructional and evidentiary errors required reversal or reduction of the second-degree murder conviction.

## Decision

- The Court of Appeal modified the judgment by reducing the conviction from second-degree murder to manslaughter.
- The court concluded the record established an unlawful homicide and criminal responsibility, but did not reliably support a finding of malice sufficient for second-degree murder under properly framed diminished-capacity principles.
- The court identified inadequate instructions connecting mental-disease evidence to malice and degree of homicide, with additional trial rulings limiting the jury’s consideration of mental and cultural factors.
- Rather than ordering a new trial, the court exercised its authority to reduce the degree of the offense because the evidence clearly supported at least manslaughter.

## Legal Principles

- When substantial evidence raises a defense or theory materially affecting guilt or degree, the trial court must provide appropriate instructions necessary for the jury to apply the law to the evidence.
- Evidence of mental disease or defect may be relevant to diminished capacity and may negate the mental element of murder, including malice aforethought, thereby reducing the offense to manslaughter.
- Standard murder instructions on implied malice may be insufficient if they do not meaningfully relate the prosecution’s burden on malice to substantial mental-impairment evidence.
- Trial courts have discretion over expert qualification and scope of expert testimony, but evidentiary limitations that prevent the jury from evaluating relevant mental-state evidence may contribute to reversible or degree-reducing error.
- An appellate court may modify a judgment to a lesser included offense when the record supports the lesser offense but does not support the greater offense under correct legal standards.

## Conclusion

The court reduced Poddar’s second-degree murder conviction to manslaughter because the jury was not adequately instructed on how substantial mental-impairment evidence could negate malice and because evidentiary restrictions, considered with the instructional defects and signs of juror confusion, undermined the reliability of the malice finding.


People v. Poddar, 26 Cal. App. 3d 438, 103 Cal. Rptr. 84 (Ct. App. 1972)