## Facts

- Williams was charged with forcible rape based on an encounter in a hotel room.
- The complaining witness testified she went to the room to watch television, and Williams—larger and heavier—hit her, prevented her from leaving, threatened her, and forced intercourse without consent.
- Williams claimed the witness willingly went to the room, initiated sexual contact, and became angry after he refused to pay money she demanded.
- The evidentiary record did not include substantial evidence of ambiguous or equivocal conduct by the witness that could reasonably be interpreted as consenting.

## Issues

1. In a forcible rape prosecution, must a trial court instruct the jury on a defense of reasonable and good-faith mistaken belief in consent whenever requested, or only when supported by substantial evidence—specifically, evidence of the victim’s equivocal conduct that could lead to such a mistaken belief?

## Decision

- The California Supreme Court reversed the Court of Appeal and reinstated the conviction.
- The trial court properly refused the requested mistake-of-fact-as-to-consent instruction.
- The instruction is not permitted absent substantial evidence that the victim engaged in equivocal conduct that could have produced a reasonable, good-faith mistaken belief in consent.

## Legal Principles

- A mistake-of-fact defense as to consent in forcible rape has both:
  - a subjective component (the defendant honestly believed there was consent), and
  - an objective component (the belief was reasonable under the circumstances).
- A defendant’s assertion of belief in consent, standing alone, does not justify the instruction; there must be record evidence of the victim’s conduct that could reasonably support the belief.
- Trial courts must give requested defense instructions only when supported by substantial evidence sufficient for a rational jury to find the defense applicable.
- In this context, “substantial evidence” requires more than speculative support and ordinarily requires evidence of the victim’s equivocal conduct that could reasonably be misread as consent.

## Conclusion

The court held that a reasonable-and-good-faith mistake-of-fact instruction on consent in a forcible rape case is unavailable without substantial evidence that the victim’s conduct was equivocal in a way that could reasonably lead to a mistaken belief in consent; because the record lacked such evidence, the conviction was reinstated.


People v. Williams, 4 Cal. 4th 354, 841 P.2d 961 (Cal. 1992)