## Facts

- Michael Mitchell Paul and his wife, Darlene Paul, lived on the Gila River Indian Reservation.
- During a late-night argument and physical fight, Paul strangled Darlene and banged her head against the ground.
- Paul showered, changed clothes, went to his mother’s house, and reported that he thought he had killed Darlene; his mother called police.
- A Bureau of Indian Affairs officer handcuffed Paul, returned with him to the home, entered through an indicated open door, and found Darlene dead.
- Paul’s trial theory was that he did not intend to kill Darlene and that her death resulted from an accidental fall during the fight.

## Issues

1. Whether the district court committed plain error by instructing on voluntary and involuntary manslaughter in a way that failed to distinguish their different mental-state requirements under 18 U.S.C. § 1112.
2. Whether the warrantless entry into Paul’s home and resulting seizure of evidence violated the Fourth Amendment.

## Decision

- The Ninth Circuit reversed Paul’s voluntary manslaughter conviction and remanded.
- The court held the jury instructions were plain error because they failed to adequately distinguish the mental states for voluntary versus involuntary manslaughter.
- The court concluded the error affected substantial rights, particularly given Paul’s defense that the death was accidental.
- The court did not grant relief on the Fourth Amendment issue; reversal rested on the instructional error.

## Legal Principles

- Under 18 U.S.C. § 1112, voluntary manslaughter requires an intentional killing (intent without malice) committed upon a sudden quarrel or heat of passion.
- Involuntary manslaughter covers unintentional killings caused by an unlawful act not amounting to a felony or by a lawful act performed without due caution and circumspection (criminal negligence).
- Jury instructions must clearly communicate the mens rea distinction between voluntary and involuntary manslaughter; collapsing “killed” into “death resulting from defendant’s act” can improperly remove the intent element from voluntary manslaughter.
- Plain error warrants reversal when an obvious instructional defect affects substantial rights and seriously affects the fairness and integrity of the proceedings.

## Conclusion

The court reversed and remanded because the jury was not properly instructed on the distinct intent requirements separating voluntary manslaughter from involuntary manslaughter, creating a substantial risk that Paul was convicted of the greater offense without a required finding of intent.


United States v. Paul, 37 F.3d 496 (9th Cir. 1994)