State v. Chyung

Summary

The court held that guilty verdicts for murder and first-degree manslaughter with a firearm were legally inconsistent because the offenses required mutually exclusive mental states as applied to the same act and result. The defendant was not required to request a jury instruction before raising the inconsistency claim in a motion for a new trial, and both verdicts therefore had to be vacated. The court also upheld the admission of prior misconduct evidence to prove intent and rebut accident, concluding that the trial court had not abused its discretion.