## Facts

- Eugene Pete Garcia, Joe Anthony Contreras, and David Lucero were federal inmates at the U.S. Penitentiary in Marion, Illinois.
- A jury convicted all three of second-degree murder of inmate Michael Martinez (18 U.S.C. § 1111) and illegal conveyance of a weapon in a federal prison (18 U.S.C. § 1792).
- Martinez was stabbed to death on November 6, 1978, after an initial struggle that began behind a partially closed door and then moved into a corridor.
- Guards testified they saw the defendants chase Martinez down the hall, catch him, and stab him while disregarding orders to stop.
- The defense presented inmate testimony that Martinez had threatened Garcia and initiated the encounter by attacking Garcia with a knife.
- The defendants did not dispute causing Martinez’s death; Garcia claimed self-defense, and Contreras and Lucero claimed they acted to aid Garcia’s defense.
- Before trial, the district court reviewed the victim’s prison file in camera and ordered partial disclosure while permitting nondisclosure of sensitive information, including an informant’s identity.

## Issues

1. Whether the evidence supported a jury instruction limiting self-defense if the defendant provoked the confrontation, requiring exhaustion of reasonable alternatives before using deadly force.
2. Whether restricting disclosure of portions of the victim’s prison file after in camera review violated the defendants’ rights or warranted reversal.
3. Whether other evidentiary and instructional rulings deprived defendants of a fair trial.

## Decision

- The Seventh Circuit affirmed the convictions.
- The court held the self-defense charge, including the provocation qualification, was properly submitted because the record allowed a reasonable inference that Garcia armed himself and went to confront Martinez in anticipation of a confrontation.
- The court upheld the district court’s in camera review and partial disclosure of the prison file, finding no showing that withheld material contained outcome-affecting exculpatory information.
- The court rejected remaining trial-error claims, concluding the defendants received a fair trial and no asserted error justified reversal.

## Legal Principles

- A trial court may instruct the jury on a limitation to self-defense based on provocation when there is sufficient evidence for a rational jury to find the defendant provoked or sought out the encounter.
- When a defendant is found to have provoked the difficulty, self-defense may be conditioned on a reasonable belief of imminent deadly danger and the prior use of reasonable alternatives short of deadly force (as framed by the jury instructions upheld on appeal).
- Discovery involving sensitive prison materials may be managed through protective procedures, including in camera review and partial disclosure, without reversible error absent a showing that nondisclosure suppressed material exculpatory evidence.
- Appellate review of evidentiary rulings and jury instructions focuses on whether, taken as a whole, they fairly and correctly state the law and whether any error prejudiced substantial rights.

## Conclusion

The court affirmed the prison homicide convictions, holding that evidence supported instructing the jury on provocation-related limits to self-defense and that the district court’s protective handling of the victim’s prison file and other trial rulings did not deny a fair trial.


United States v. Garcia, 625 F.2d 162 (7th Cir. 1980)