Dixon v. Williams

Erroneous jury instruction regarding self-defense was not harmless because it limited the jury's consideration of what constitutes manslaughter instead of murder.

Frederic Dixon is serving a sentence of life with the possibility of parole for a second-degree murder conviction. Dixon claimed he shot the man in self-defense. Part of the jury instructions in the criminal trial stated, "an honest but reasonable belief in the necessity for self-defense does not negate malice and does not reduce the offense from manslaughter to murder." The instruction should have read "honest but unreasonable." Dixon appealed his conviction and the Nevada Supreme Court affirmed the conviction by applying a "harmless error analysis." Dixon then filed a federal habeas corpus petition. On appeal, the Ninth Circuit held that under Nevada law, the trial record as a whole shows that enough evidence existed for the jury to have found that Dixon acted with provocation, not enough to escape conviction, but enough to reduce the offense to manslaughter. The panel held that the erroneous jury instruction limited the jury's ability to reduce the offense to manslaughter and violated Dixon's Fourteenth Amendment rights. REVERSED and REMANDED.