State v. Hanton
Supreme Court of Washington
614 P.2d 1280 (1980)
After Solomon Hanton (defendant) cut off another driver, the angry driver followed him to a stoplight, got out, opened Hanton's car door, and tried to pull him out; Hanton then drew a pistol and shot the man, who died days later. Hanton was charged with first-degree manslaughter, and the trial court instructed the jury that Hanton bore the burden of producing some evidence of self-defense, but did not have to prove it beyond a reasonable doubt or by a preponderance. Hanton was convicted, and the court of appeals affirmed before the state supreme court granted review.
Whether, in a prosecution for first-degree manslaughter in Washington, the State bears the burden of proving the absence of self-defense beyond a reasonable doubt.