## Facts

- Daryl Randle was discovered taking stereo equipment from a car belonging to Charles Lambert, who lived with his cousin Brian Robinson.
- Robinson confronted Randle and threatened to beat him; Randle drew a .25-caliber pistol and fired several shots as he fled with his younger cousin, Byron W., who carried stolen equipment.
- Robinson and Lambert pursued the fleeing pair in a truck, caught Byron, and beat him; after Byron fell, Robinson kicked him, and the beating continued for several minutes.
- Lambert left to get Robinson’s father while Robinson resumed attacking Byron; testimony described severe kicking and stomping.
- Randle returned, heard Byron yelling for help and a statement that Byron would be killed, and saw Byron being beaten on the ground.
- Randle yelled for the beating to stop and fired toward the attackers; a bullet struck and killed Robinson.
- At trial, Randle sought instructions on imperfect defense of another (actual but unreasonable belief in the need to defend Byron); the court refused and instructed on a broad “escape rule” limiting defensive rights of a fleeing felon.

## Issues

1. Whether an actual but unreasonable belief in the need to defend a third person from imminent death or great bodily injury negates malice and reduces murder to voluntary manslaughter (imperfect defense of others).
2. Whether the trial court erred by refusing to instruct on imperfect defense of others when supported by the evidence.
3. Whether the trial court’s instructions on perfect defense of others and the “escape rule” misstated California law and, if so, whether the errors were prejudicial.

## Decision

- The California Supreme Court held that California recognizes imperfect defense of others: a defendant who kills under an actual but unreasonable belief in the need to defend another lacks malice and is guilty of voluntary manslaughter, not murder.
- The court concluded the failure to instruct on imperfect defense of others was error but harmless on this record.
- The court held the “escape rule” instruction was an overbroad misstatement that improperly suggested a fleeing burglar/robber has no right to self-defense or defense of others beyond reaching temporary safety, regardless of later circumstances.
- Because the erroneous escape-rule instruction undermined the jury’s consideration of both perfect and imperfect defense of others, the instructional error was prejudicial.
- The court reversed the Court of Appeal’s judgment and remanded for further proceedings.

## Legal Principles

- Imperfect defense of others is a form of voluntary manslaughter: an intentional killing committed under an actual but unreasonable belief in the need to protect another from imminent death or great bodily injury negates malice aforethought.
- Imperfect defense of others follows the same malice-negation rationale as imperfect self-defense; it is mitigation, not a complete justification.
- Perfect defense of others may justify homicide when the defendant reasonably believes deadly force is necessary to prevent imminent death or great bodily injury to another.
- Jury instructions must not categorically withdraw self-defense or defense-of-others rights through an overbroad “escape rule” when the facts show the immediate felony has ended and the asserted defensive force responds to a separate, ongoing threat of serious harm.
- Prejudice exists when an instructional misstatement creates a reasonable probability the jury’s verdict was affected by restricting consideration of a supported defense theory.

## Conclusion

The court recognized imperfect defense of others as voluntary manslaughter mitigation because an actual but unreasonable belief in the need to protect another negates malice, and it reversed due to prejudicial instructional error from an overbroad escape-rule charge that impaired the jury’s ability to evaluate defense-of-others theories.


People v. Randle, 35 Cal. 4th 987 (Cal. 2005)