Commonwealth v. Kenneth Jose Santana-Rodriguez

Summary

The court held that a defendant's lawful self-defense against an assailant may excuse the unintended killing of an innocent bystander under transferred intent principles. The defense is partial, however, because the defendant may still be convicted of involuntary manslaughter if the self-defense was wanton or reckless and created a high degree of likelihood that substantial harm would result to the bystander. The court remanded for further proceedings and provided a provisional model jury instruction.