Does a jury error in failing to instruct the jury on self-defense constitute a harmless beyond a reasonable doubt?

California, United States of America


The following excerpt is from People v. Watie, 100 Cal.App.4th 866, 124 Cal.Rptr.2d 258 (Cal. App. 2002):

Based on this record, and for the reasons that follow, we conclude any error in failing to instruct the jury on self-defense, as it related to the section 246 offense, was harmless beyond a reasonable doubt, that is, "the guilty verdict actually rendered in this trial was surely unattributable to the error." (Sullivan v. Louisiana (1993) 508 U.S. 275, 279, 113 S.Ct. 2078, 124 L.Ed.2d 182, 189.)

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