United States v. Michael Mitchell Paul

Michael Mitchell Paul was convicted of voluntary manslaughter in violation of 18 U.S.C. § 1112 . The district court instructed the jury using the Ninth Circuit model jury instructions for voluntary and involuntary manslaughter. We hold that the district court’s instructions constituted plain error because they failed to adequately distinguish the different mental state requirements of voluntary and involuntary manslaughter. Therefore, we reverse Paul’s conviction.

BACKGROUND FACTS

On July 18,1992, Darlene Paul died during a fight with her husband Michael Paul at their home on the Gila River Indian Reservation. Paul claims his wife came home drunk around one o’clock in the morning. According to Paul, Darlene wouldn’t tell him where their 2)t year old son, Joshua, was. An argu ment ensued during which the two traded personal insults and accusations leading to violence. During the fight, Paul strangled Darlene and banged her head against the ground. Believing he killed her, Paul took a shower to wash blood off himself and changed into new clothes. He then went to his mother’s house, told her he thought he killed Darlene, and instructed her to call the police to come pick him…