Marquinn Jones-Nelson v. State of Alaska

Summary

The Alaska Supreme Court held that the trial court’s supplemental self-defense instruction was legally erroneous because it invited retrospective assessment of necessity and incorrectly distinguished between ordinary and “all-out” deadly force. The defendant preserved his objection, and the error improperly reduced the State’s burden to disprove self-defense beyond a reasonable doubt; the State failed to establish harmlessness beyond a reasonable doubt. The court reversed the court of appeals, vacated the conviction, and remanded for further proceedings.