State of Utah, Plaintiff and Respondent v. Paul Leo Knoll, Defendant and Appellant

Summary

The court affirmed Knoll’s manslaughter conviction, holding that absence of self-defense is not a prima facie element of homicide. Nevertheless, once self-defense is raised by any evidence, the prosecution must prove beyond a reasonable doubt that the killing was not justified, and the jury must acquit if reasonable doubt remains. The court concluded that the instructions adequately conveyed these principles and that the evidence supported the jury’s rejection of self-defense.