United States of America v. William Clayton Brown

Muskogee, Oklahoma criminal defense lawyer represented the Defendant charged with first-degree murder in Indian Country.



Defendant William Clayton Brown, while under the influence of methamphetamine, busted into a locked bathroom and stabbed his friend, Damion Martin, in the back of his skull. Martin was embracing Defendant's sister, Lacie Watson, who was naked except for a shower curtain she had wrapped around her body. Defendant was unaware Martin and Watson had a prior intimate relationship. What Defendant did know, however, was that Watson had just yelled at Martin to "get the fuck out” of the bathroom. Seconds later, Defendant entered the bathroom and stabbed Martin twice, killing him. When Watson asked why he stabbed Martin, Defendant exclaimed, "He was going to kill you, Lacie.” After the stabbing, Defendant told three other people Martin had threatened to rape Watson.



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The Government tried Defendant on one count of First-Degree Murder in Indian Country, in violation of 18 U.S.C. §§ 1111(a), 1151 and 1153. Defendant requested jury instructions on defense of another and the lesser-included offense of involuntary manslaughter. The district court refused to instruct the jury on defense of another, holding there was insufficient evidence Defendant's claim was objectively reasonable. But the court also omitted, without explanation, Defendant's requested involuntary manslaughter instruction raising the theory of imperfect defense of another. Defendant argues this omission was plainly erroneous. We agree. A defendant is entitled to a jury instruction on imperfect defense of another and the corresponding lesser-included offense of involuntary manslaughter if he tenders such an instruction and produces sufficient evidence that he subjectively believed deadly force was necessary to prevent death or great bodily harm to another, notwithstanding the fact that his belief was objectively unreasonable. Defendant met that standard here. Exercising jurisdiction under 28 U.S.C. § 1291, we reverse Defendant's conviction and remand for a new trial.

Reversed