State v. Thille

Summary

The court affirmed Thille's reckless second-degree murder conviction, holding that the evidence did not support voluntary manslaughter instructions based on imperfect self-defense or sudden quarrel. Although the court concluded that an involuntary manslaughter instruction was factually appropriate, its omission was not clear error because Thille failed to show that the jury would probably have reached a different verdict. The court applied an objective reasonable-person standard to sufficient provocation and required evidence of a subjective belief in the necessity of deadly force for imperfect self-defense.