State v. Lawton

William Lawton (defendant) was badly beaten by up to eight or ten people in a bar, leaving his face swollen and deformed with one eye shut. He went home, retrieved a handgun, returned to the bar about ten minutes later, and shot and killed someone he believed was one of his attackers. The State of New Jersey (plaintiff) charged Lawton with first-degree murder; the trial court instructed the jury on both murder and manslaughter but did not make clear that the state had to prove beyond a reasonable doubt that Lawton did not act in the heat of passion with reasonable provocation. The jury convicted Lawton, his direct appeal failed, and after his motion for post-conviction relief was denied, he appealed again.