California Legal Brief

The Rule of People v. Chang is that imperfect self-defense is unavailable when a defendant's belief in the need for self-defense is based entirely on delusion without any objective correlate that could plausibly relate to a reasonable need for self-defense, under circumstances where the defendant shoots at peace officers based solely on delusional beliefs about CIA persecution without any objective threatening conduct by the officers.

Appeal from judgment after jury trial in Superior Court, Tulare County.

Defendant Appellant was Marvin Joseph Chang — the convicted felon who shot at multiple peace officers during a high-speed chase while under the delusion that they were CIA agents trying to kill him.

Plaintiff Respondent was The People — the prosecuting authority seeking convictions for attempted murder and related charges.

The suit sounded in criminal prosecution for attempted murder, assault on peace officers, and related firearm offenses arising from a police chase and gun battle.

The key substantive facts leading to the suit were that Chang, suffering from schizoaffective disorder with delusions about CIA persecution, threatened a woman at a gas station, fired shots, then led police on a high-speed chase while firing at officers from his vehicle. He wounded Officer Wilson during a gun battle in an orchard. Chang testified he believed all police officers were working with the CIA to kill him and that he was a "lightworker" fighting evil forces.

The procedural result leading to the Appeal: The trial court denied Chang's request for an imperfect self-defense instruction, ruling that his belief in the need for self-defense was entirely based on delusion without objective correlate, citing People v. Elmore (2014) 59 Cal.4th 121.

The key question(s) on Appeal: Whether the trial court erred in refusing to give an imperfect self-defense instruction when defendant's belief in the need for self-defense was based entirely on delusions about CIA persecution.

The Appellate Court held that the trial court properly refused the imperfect self-defense instruction because defendant's belief was purely delusional without any objective correlate that could plausibly relate to a reasonable need for self-defense, as the officers engaged in no threatening conduct before defendant began shooting and their mere presence as peace officers conducting a lawful traffic stop cannot constitute an objective correlate for self-defense.

The case is inapplicable when there is an objective correlate that could plausibly relate to a reasonable need for self-defense (such as a victim brandishing a weapon or making threatening gestures), when officers engage in objectively threatening conduct before defendant acts, or when defendant's belief, though unreasonable, is based on misinterpretation of actual threatening facts rather than pure delusion.

The case leaves open what specific police conduct might constitute sufficient objective correlate for imperfect self-defense, the boundaries of when officer weapon display could support the instruction, and how courts should analyze mixed cases involving both delusional and factually-based beliefs.