The following excerpt is from Armas v. Cate, Case No. 1:11-cv-00772-SKO-HC (E.D. Cal. 2014):
error, but if error was harmless because it had no substantial or injurious effect or influence in determining the jury's verdict where numerous instructions allowed the jury to consider the effect of threats upon the accused's mental state, both as an absolute defense to all charges and as a factor in choosing between first and second degree murder; the jury had been given more than the simple all or nothing choice at issue in Beck v. Alabama, 447 U.S. 625, 638-46 (1980); and the jury's decision to reject second degree murder meant that they would not have accepted the lesser charge of manslaughter).
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