People v. Humphrey

BROWN, J., Concurring.

For years the lower courts, poised precariously upon the slippery slope of personalized defenses, have tried valiantly not to ski down it. Early cases focused on the general admissibility of evidence of battered woman’s syndrome (BWS) to support claims of self-defense. By 1991, with that question answered by legislative fiat, concern shifted to a more nuanced discussion of relevance. Courts found expert testimony admissible to rehabilitate the defendant’s credibility and to explain her subjective state of mind, but not relevant to the jury’s determination of the objective reasonableness of her actions.

Today we hold that “evidence of battered women’s syndrome is generally relevant to the reasonableness, as well as the subjective existence, of defendant’s belief in the need to defend and, to the extent it is relevant, the jury may consider it in deciding both questions.” (Maj. opn., ante, at pp. 1088-1089.) But, this conclusion only begins, rather than ends, the discussion. As always, the devil is in the details.

*1093Substantial questions remain unresolved: when, to what purpose, and to what extent can expert opinion concerning the defendant’s mental state be used to assess the objective reasonableness of a claim of self-defense? If we go too far, accountability—the essential touchstone of the criminal law—is undermined; if we do not go far enough, the defendant is deprived of a defense the jury may find genuine. It is the struggle to find the balance point between accountability and justification that engenders confusion when a victim of battering kills her abuser and seeks to prove her claim of self-defense with BWS evidence.

While I agree with the general conclusions of the majority, concern with the specific application of these principles prompts me to examine more closely the links between the objective component of self-defense and BWS.

The Law of Self-defense

The statutory basis for self-defense, as described in Penal Code sections 197 and 198, permits killing to prevent great bodily injury or death when there is “reasonable ground” to believe such harm is threatened and “imminent danger” of the threat “being accomplished . . . .” (Pen. Code, § 197.) Nevertheless, “[a] bare fear of the commission of [great bodily injury] is not sufficient to justify it. But the circumstances must be sufficient to excite the fears of a reasonable person, and the party killing must have acted under the influence of such fears alone.” (Pen. Code, § 198.)

Accordingly, “self-defense may be analyzed as having two requirements: (1) the defendant’s acts causing the victim’s death were motivated by an actual (also referred to as ‘genuine’ or ‘honest’) belief or perception that (a) the defendant was in imminent danger of death or great bodily injury from an unlawful attack or threat by the victim and (b) the defendant’s acts were necessary to prevent the injury; and (2) a reasonable person in the same circumstances would have had the same perception and done the same acts.” (People v. Aris (1989) 215 Cal.App.3d 1178, 1186 [264 Cal.Rptr. 167].) Or, as reduced to the common shorthand: “self-defense requires both actual subjective belief and objective reasonableness . . . .” (Ibid.)

“Justification does not depend upon the existence of actual danger but rather depends upon appearances; it is sufficient that the circumstances be such that a reasonable person would be placed in fear for his safety and that the defendant acted out of that fear. [Citations.]” (People v. Clark (1982) 130 Cal.App.3d 371, 377 [181 Cal.Rptr. 682].) The defendant may well be mistaken in his assessment of the circumstances; but if reasonably so, he is nevertheless entitled to the defense. (People v. Semone (1934) 140 Cal.App. *1094318, 327 [35 P.2d 379]; see People v. Toledo (1948) 85 Cal.App.2d 577, 580 [193 P.2d 953].) In the words of Justice Holmes, “Detached reflection cannot be demanded in the presence of an uplifted knife.” (Brown v. United States (1921) 256 U.S. 335, 343 [65 L.Ed. 961, 963, 41 S.Ct. 501, 18 A.L.R. 1276].) “In defending himself, however, a person may use only that force which is necessary in view of the nature of the attack .... [Citation.]” (People v. Clark, supra, 130 Cal.App.3d at p. 377.)

The law thus recognizes that the objective component is not measured by an abstract standard of reasonableness but one based on the defendant’s perception of imminent harm or death. Because his state of mind is a critical issue, he may explain his actions in light of his knowledge concerning the victim. (People v. Davis (1965) 63 Cal.2d 648, 656 [47 Cal.Rptr. 801, 408 P.2d 129]; see People v. Lee Chuck (1887) 74 Cal. 30, 34-35 [15 P. 322].) Antecedent threats as well as the victim’s reputation for violence, prior “assaults, and other circumstances [are] relevant to interpreting the attacker’s behavior.” (People v. Aris, supra, 215 Cal.App.3d at p. 1189; see People v. Moore (1954) 43 Cal.2d 517, 527-529 [275 P.2d 485]; People v. Lee Chuck, supra, 74 Cal. at pp. 34-35; People v. Brophy (1954) 122 Cal.App.2d 638, 647-648 [265 P.2d 593].) While such considerations alone do not establish a right of self-defense (see People v. Fitch (1938) 28 Cal.App.2d 31, 45-46 [81 P.2d 1019]), they illuminate and reflect on the reasonableness of defendant’s perception of both the imminence of danger and the need to resist with the degree of force applied. (See People v. Moore, supra, 43 Cal.2d at p. 528.) They may also justify the defendant “in acting more quickly and taking harsher measures for her own protection in the event of assault, whether actual or threatened, than would a person who had not received such threats.” (People v. Bush (1978) 84 Cal.App.3d 294, 302-303 [148 Cal.Rptr. 430].)

Imminence is a critical component of both prongs of self-defense. A previous threat, unaccompanied by any demonstration of an immediate intention and ability to carry it out, will not justify an assault. The defendant is, however, “entitled to corroborate his testimony that he was in [immediate or imminent] fear for his life by proving the reasonableness of such fear” through evidence of “his own frame of mind.” (People v. Davis, supra, 63 Cal.2d at p. 656.) The jury must evaluate such perceptions in context, i.e., the “same or similar circumstances” as those in which the defendant acted. (See People v. Kermott (1939) 33 Cal.App.2d 236, 242-243 [91 P.2d 215].) Therefore, if they would “induce a well founded belief in the mind of a reasonable person that his adversary was on the eve of executing the threat” and that immediate defense against the impending danger was the only means of escape from great bodily injury or death, the law of self-defense *1095justifies use of whatever force is necessary to “avert the threatened peril.” (People v. Scoggins (1869) 37 Cal. 676, 683-684; People v. Aris, supra, 215 Cal.App.3d at pp. 1186-1189.)

The General Relevance of BWS

Evidence Code section 1107 makes admissible relevant expert testimony regarding BWS, “including the physical, emotional, or mental effects upon the beliefs, perceptions, or behavior of victims of domestic violence.” The statute further allows that this evidence “shall not be considered a new scientific technique whose reliability is unproven” (Evid. Code, § 1107, subd. (b)), thus legislatively obviating the need to qualify the expert’s testimony under the standards of People v. Kelly (1976) 17 Cal.3d 24, 30 [130 Cal.Rptr. 144, 549 P.2d 1240]. (See People v. Leahy (1994) 8 Cal.4th 587, 593-604 [34 Cal.Rptr.2d 663, 882 P.2d 321]; but see Ibn-Tamas v. United States (D.C. 1979) 407 A.2d 626, 655 (dis. opn. of Nebeker, J.); Note, The Battered Woman Syndrome and Self-Defense: A Legal and Empirical Dissent (1986) 72 Va. L.Rev. 619, 630-643.) However, since section 1107 does not specifically abrogate Evidence Code section 801, we may assume that section’s definition of the foundational prerequisites for expert testimony remains integral to the assessment of relevance. Thus, not only must the proponent establish the expert’s qualifications (Evid. Code, § 801, subd. (b); id., § 1107, subd. (b)), the testimony must “[r]elate[] to a subject that is sufficiently beyond common experience that the opinion of an expert would assist the trier of fact . . . .” (Id., § 801, subd. (a); People v. Cole (1956) 47 Cal.2d 99, 103-104 [301 P.2d 854, 56 A.L.R.2d 1435].)

With respect to psychological states analogous to BWS, such as rape trauma syndrome and child sexual abuse accommodation syndrome, courts, including this one, have generally held expert opinion admissible for the same general reason defendants proffer testimony on BWS; “to disabus[e] the jury of some widely held misconceptions about [the] victims, so that it may evaluate the evidence free of the constraints of popular myths. [Citations.]” (People v. Bledsoe (1984) 36 Cal.3d 236, 247-248 [203 Cal.Rptr. 450, 681 P.2d 291] [rape]; People v. Sanchez (1989) 208 Cal.App.3d 721, 735 [256 Cal.Rptr. 446] [child sexual abuse]; cf. People v. McAlpin (1991) 53 Cal.3d 1289, 1300-1302 [283 Cal.Rptr. 382, 812 P.2d 563] [expert testimony admissible to dispel misconceptions about reporting of child molestation].) Nevertheless, consistent with the fundamental requisite of relevancy, admissibility is not unqualified. For example, in child molestation cases “the prosecution is obligated to ‘identify the myth or misconception the evidence is designed to rebut’ and the testimony must be limited to exposing the misconception by explaining why the child’s behavior is not *1096inconsistent with his or her having been abused. [Citation.]” (People v. Bothuel (1988) 205 Cal.App.3d 581, 587 [252 Cal.Rptr. 596], overruled on other grounds in People v. Scott (1994) 9 Cal.4th 331, 348 [36 Cal.Rptr.2d 627, 885 P.2d 1040]; People v. Bowker (1988) 203 Cal.App.3d 385, 394 [249 Cal.Rptr. 886].) The jury should also be given a limiting instruction. (People v. Bergschneider (1989) 211 Cal.App.3d 144, 159 [259 Cal.Rptr. 219].)

The Specific Issue of Objective Reasonableness

The foregoing substantive and evidentiary principles direct the present inquiry: we must identify those aspects of BWS not only sufficiently beyond the ken of the average juror to warrant expert testimony but also specifically relevant to the jury’s determination whether the defendant had “a reasonable belief that [she would] lose [her] life or suffer serious bodily injury unless [she] immediately defended] [herself] against the attack of the adversary.” (People v. Scoggins, supra, 37 Cal. at p. 683.)

Despite the extensive and vivid, even lurid, details of battering relationships, the literature and published opinions contain relatively limited discussion, even on an anecdotal basis, of BWS directly relating to objective reasonableness. The single most pertinent aspect, which defendant here invokes, is the hypervigilance generated by the cycles of abuse that mark these relationships. As the commentators explain: “[T]he battered woman’s familiarity with her husband’s violence may enable her to recognize the subtle signs that usually precede a severe beating. . . . Moreover, even if the woman kills her husband when he is only threatening her, rather than actually beating her, she knows from past experience that he is not merely making idle comments but is fully capable of carrying out his threats. Thus, the battered woman may reasonably fear imminent danger from her husband when others unfamiliar with the history of abuse would not.” (Kinports, Defending Battered Women’s Self-Defense Claims (1988) 67 Or. L.Rev. 393, 423-424, fns. omitted; Crocker, The Meaning of Equality for Battered Women Who Kill Men in Self-Defense (1985) 8 Harv. Women’s L.J. 121, 141, 143; Walker, Battered Women Syndrome and Self-Defense (1992) 6 Notre Dame J.L. Ethics & Pub. Pol’y 321, 324, 328.) “[E]xperts testify that, because a battered woman is attuned to her abuser’s pattern of attacks, she learns to recognize subtle gestures or threats that distinguish the severity of attacks and that lead her to believe a particular attack will seriously threaten her survival.” (Developments in the Law—Legal Responses to Domestic Violence (1993) 106 Harv. L.Rev. 1498, 1582, fn. omitted.)

In a related vein, researchers also note that “[w]hen a woman kills her batterer, the abuse almost always will have escalated both in frequency and *1097intensity in the period immediately preceding the killing.” (Rosen, On Self-Defense, Imminence, and Women Who Kill Their Batterers (1993) 71 N.C. L.Rev. 371, 401, fn. omitted; see Walker et al., Beyond the Juror’s Ken: Battered Women (1982) 7 Vt. L.Rev. 1, 3; Browne, When Battered Women Kill (1987) pp. 68-69, 105-107.) “Expert testimony [shows] that among battered women who kill, the final incident that precipitates the killing is viewed by the battered woman as ‘more severe and more life-threatening than prior incidents.’ [Citation.]” (Commonwealth v. Stonehouse (1989) 521 Pa. 41, 63 [555 A.2d 772, 784], fn. omitted.) On the basis of her experience, a battered woman may thus be “better able to predict the likely degree of violence in any particular battering incident” (Ewing, Battered Women Who Kill (1987) p. 55) and in turn may more precisely assess the measure and speed of force necessary to resist. (People v. Aris, supra, 215 Cal.App.3d at p. 1194.)

Judicial analysis reflects the relevance of BWS to the objective component of self-defense. In State v. Kelly (1984) 97 N.J. 178,193 [478 A.2d 364, 371], the trial court had excluded expert evidence on BWS. The New Jersey Supreme Court reversed and observed, “Depending on its content, the expert’s testimony might also enable the jury to find that the battered wife, because of the prior beatings, numerous beatings, as often as once a week, for seven years, from the day they were married to the day he died, is particularly able to predict accurately the likely extent of violence in any attack on her. That conclusion could significantly affect the jury’s evaluation of the reasonableness of defendant’s fear for her life.” (478 A.2d at p. 378, fn. omitted; Robinson v. State (1992) 308 S.C. 74 [417 S.E.2d 88, 91] [“battered women can experience a heightened sense of imminent danger arising from the perpetual terror of physical and mental abuse”].)

In People v. Torres (1985) 128 Misc.2d 129 [488 N.Y.S.2d 358], the trial court also rejected proffered expert testimony. The reviewing court found error; the evidence was relevant in part because the expert “would testify that a battered woman, through her extensive experience with prolonged physical abuse, learns to distinguish between varying degrees of danger and violence. This expert explanation concerning acute discriminatory powers would provide a basis for the jury to understand how at the time of the shooting [the batterer’s] violence had, in the defendant’s mind, passed from the ‘normal’ and tolerable into the ‘abnormal’ and life-threatening.” (488 N.Y.S.2d at p. 362.) By placing the final incidence of abuse in context, the testimony might enlighten the jury’s assessment of a reasonable person’s perceptions as well. (See also State v. Gallegos (1986) 104 N.M. 247 [719 P.2d 1268, 1271] [“Incidents of domestic violence tend to follow predictable patterns. Recurring stimuli, such as drunkenness or jealousy, reliably incite *1098brutal rages. Remarks or gestures which are merely offensive or perhaps even meaningless to the general public may be understood by the abused individual as an affirmation of impending physical abuse.”]; State v. Allery (1984) 101 Wn.2d 591, 597 [682 P.2d 312, 316] [“[E]xpert testimony explaining why a person suffering from [BWS] would . . . fear increased aggression against herself would be helpful to a jury in understanding a phenomenon not within the competence of an ordinary lay person” and also “is central to her claim of self-defense. [Citation.]”].)

There is a clear nexus between the phenomenon of hypervigilance and the objective component of self-defense, i.e., the reasonable fear of imminent injury or death and the perceived need to react with the speed and force used. Under settled principles, if the victim’s threats caused the defendant “ ‘to fear greater peril than she would have had otherwise, [the jury may] take such facts into consideration in determining whether defendant acted in a manner which a reasonable person would act in protecting his or her own life or bodily safety.’ ” (People v. Moore, supra, 43 Cal.2d at p. 528.) For the same reasons, the defendant may also be “ ‘justified in acting more quickly and taking harsher measures for her own protection in event of assault, than would a person who had not received such threats ....’” (Ibid.; People v. Bush, supra, 84 Cal.App.3d at p. 304; People v. Torres (1949) 94 Cal.App.2d 146, 152-153 [210 P.2d 324].) When antecedent threats have accompanied a recurring cycle of escalating abuse, their relevance to the reasonableness of the defendant’s fear of imminent and more serious violence is manifest.

Although relevant to the objective component of self-defense, BWS evidence is necessarily subject to qualifications and limitations when proffered on that issue. Evidence Code section 1107 is “a rule of evidence only”; “no substantive change affecting the Penal Code is intended.” (Evid. Code, § 1107, subd. (d).) Expert testimony is therefore not relevant until the defendant puts at issue conduct or circumstances the jury might not otherwise understand as the basis for self-defense, i.e., that absent BWS evidence would not be considered reasonable. (See Behr v. County of Santa Cruz (1959) 172 Cal.App.2d 697, 709-710 [342 P.2d 987], and cases cited; see also State v. Gallegos, supra, 719 P.2d at p. 1271; cf. People v. Bothuel, supra, 205 Cal.App.3d at p. 587.) In many circumstances, BWS will be irrelevant to the question of objective reasonableness because the facts raise a traditional and therefore readily assessable self-defense claim, for example, when the victim threatens or approaches the defendant with a gun or knife or when the two struggle over a weapon following a threat or other hostile act by the victim. In such “classic” confrontations, “[f]ear is a common human emotion within the understanding of a jury and hence expert psychiatric explanation is not necessary. A jury is as capable as [the expert] in determining the ultimate fact in this case whether [the defendant] acted under fear *1099when she shot her husband.” (State v. Griffiths (1980) 101 Idaho 163, 165 [610 P.2d 522, 524], overruled on other grounds in State v. LePage (1981) 102 Idaho 387 [630 P.2d 674, 683]; cf. People v. Czahara (1988) 203 Cal.App.3d 1468, 1478 [250 Cal.Rptr. 836] [whether events would have provoked the ordinary reasonable person to an unreasoning passion “not a subject sufficiently beyond common experience” to warrant expert opinion].)

In other circumstances, however, the situation may be confrontational but lack such overt or obvious potential for serious harm. Nevertheless, in light of her history of battering by the victim, the defendant may anticipate imminent bodily injury or death. Or, following an initial struggle in which she gained a temporary advantage, she may continue to fear the victim because she knows he reacts violently to loss of control or she senses an escalating severity to his violence. “[Where] there has been physical abuse over a long period of time, the circumstances which assist the court in determining the reasonableness of a defendant’s fear of death or serious injury at the time of a killing include the defendant’s familiarity with the victim’s behavior in the past.” (Commonwealth v. Stonehouse, supra, 555 A.2d at p. 781.) “The cyclical nature of an intimate battering relationship enables a battered spouse to become expert at recognizing the warning signs of an impending assault from her partner—signs frequently imperceptible to outsiders. For some victims, the sign may be ‘that look in his eye’; for others, it is the advent of heavy drinking, or heightened irrational jealousy.” (Banks v. State (1992) 92 Md.App. 422, 429 [608 A.2d 1249, 1252].)

Although a jury might not find the appearances sufficient to provoke a reasonable person’s fear, they might conclude otherwise as to a reasonable person’s perception of the reality when enlightened by expert testimony on the concept of hypervigilance. The expert evidence thus “is aimed at an area where the purported common knowledge of the jury may be very much mistaken, an area where jurors’ logic, drawn from their own experience, may lead to a wholly incorrect conclusion, an area where expert knowledge would enable the jurors to disregard their prior conclusions as being common myths rather than common knowledge.” (State v. Kelly, supra, 478 A.2d at p. 378; Ibn-Tamas v. United States, supra, 407 A.2d at p. 634; Hawthorne v. State (Fla.Dist.Ct.App. 1982) 408 So.2d 801, 806-807.)

Nevertheless, the expert must not usurp the function of the jury and reach the ultimate question of reasonableness. (See People v. Aris, supra, 215 Cal.App.3d at pp. 1197-1198.) The concept of hypervigilance is not the evidentiary equivalent of, or substitute for, an actual perception of impending danger, only a possible explanation for the defendant’s reaction to a perceived threat. (Cf. People v. Bledsoe, supra, 36 Cal.3d at pp. 249-251 *1100[rape trauma syndrome evidence admissible to rebut misconceptions about rape victims but not to establish crime occurred].) “Either the jury accepts or rejects that explanation .... No expert is needed, . . . once the jury has made up its mind on those issues, to tell the jury the logical conclusion, namely, that a person who has in fact been severely and continuously beaten might very well reasonably fear that the imminent beating she was about to suffer could be either life-threatening or pose a risk of serious injury.” (State v. Kelly, supra, 478 A.2d at p. 378, fn. omitted.) The determination must remain objective even though the inquiry may be individualized by consideration of BWS.

Finally, since BWS is admissible only narrowly on the issue of objective reasonableness, a limiting instruction is appropriate upon request to “restrict the evidence to its proper scope . . . .” (Evid. Code, § 355; see Daggett v. Atchison, T. & S.F. Ry. Co. (1957) 48 Cal.2d 655, 665-666 [313 P.2d 557, 64 A.L.R.2d 1283]; cf. People v. Bothuel, supra, 205 Cal.App.3d at p. 589.) In assessing a claim of self-defense the jury must not confuse the question whether a reasonable person in the defendant’s circumstances would have perceived a threat of imminent injury or death with the notion that killing the abuser would be a “reasonable,” i.e., understandable, response to ongoing physical and psychological abuse. Absent a limitation, the jury may read the instructions to imply a separate standard in BWS cases. While courts in some jurisdictions refer to the “reasonably prudent battered woman,” (Commonwealth v. Stonehouse, supra, 555 A.2d at p. 784; see also State v. Kelly, supra, 478 A.2d at p. 385, fn. 23), California maintains a single standard for all defendants who claim they acted in self-defense. Moreover, the jury must appreciate that opinion testimony is not dispositive but “only to aid in coming to a conclusion, and it does not exclude consideration of other evidence which is pertinent to the issue involved. [Citations.]” (Neel v. Mannings, Inc. (1942) 19 Cal.2d 647, 654 [122 P.2d 576].)

Application to These Facts

Turning to the facts of this case, for the most part defendant’s account of events leading to the shooting did not require the filter of an expert’s opinion to assist in determining the question of reasonableness. She presented a relatively straightforward claim of self-defense the jury could either accept or reject as such. According to defendant, Hampton had been physically and verbally abusive for most of the year they lived together. His threats and acts of violence had been increasing for several weeks prior to the fateful evening. Although he liked guns and owned several, he had never shot at her until the previous night. On the way home from the mountains the next day, he pointed out what he thought would be a good place to kill her because no *1101one would find the body for awhile. Just minutes before the shooting with the gun lying within easy reach, he told her “[t]his time” he would not miss. She then grabbed the weapon as he appeared about to do the same. While she was holding him at bay, he reached for her arm at which point she apparently shot him. On their face, nothing in these facts lies beyond the experience of the average reasonable person or the ken of the average juror. (See State v. Griffiths, supra, 610 P.2d at p. 524.)

At the same time, defendant also testified to facts implicating characteristics of BWS that correspond to the objective element of self-defense. Consistent with his threats, Hampton began hitting her more frequently when he got off parole. The night before, he was “getting crazy” asking for the gun, which he then shot in her direction narrowly missing her. At that moment, he had a “look on his face” that defendant had seen before “but not this bad”; he “wasn’t the same person.” As to events surrounding Hampton’s death, defendant related that shortly before she grabbed the gun, the two were screaming and arguing; “then all of a sudden, he got quiet for a minute or two, and, then, he just snapped.” A few moments later, he moved from the kitchen toward the gun saying, “This time, bitch, when I shoot at you, I won’t miss.” At this point, she “knew he would shoot me” and was “scared to death” not only because of Hampton’s threats and prior violence but also because of his “very, very heavy” walk indicating he was “mad.” She had no doubt he would kill her if she did not kill him first. As they confronted each other in the kitchen, he “looked crazy.” She assumed he was going for the gun when he reached for her arm and shot him.

As relevant to this testimony, Dr. Bowker explained generally that with the cycles of violence typifying BWS the “severity tends to escalate over time.” Battered women develop a heightened awareness of this escalation as threats and physical abuse become increasingly menacing. A sense of the batterer’s omnipotence due to his dominance may augment this hypervigilance, causing the woman to believe all the more he will act on his threats of violence.

Bowker also discussed some specifics arguably relating to defendant’s objective perception of imminent harm: “[T]he escalation had been such, particularly the night before, where [Hampton] actually shot at her that it would be pretty hard to doubt the seriousness.” “A difference, I think, [between Hampton’s last threat and previous ones] is that [defendant] felt for the first time that he really intended to do it and, you know, my experience with battered women who kill in self-defense their abusers, it’s always related to their perceived change of what’s going on in a relationship. They become very sensitive to what sets off batterers. They watch for this stuff very carefully. [<][] Anybody who is abused over a period of time becomes *1102sensitive to the abuser’s behavior and when she sees a change acceleration begin in that behavior, it tells them something is going to happen and usually the abuser said things specifically like ‘I’m really going to kill you this time,’ and, you know, they don’t admit to that something happens that there’s a label put on it by the abuser which was certainly true in Albert’s case and that’s intensification or an acceleration of the process is what leads to some self-defensive action which is beyond anything that the woman has ever done before.”

This testimony could assist the jury in determining whether a reasonable person in defendant’s situation would have perceived from the totality of the circumstances imminent peril of serious bodily injury or death. Absent the expert’s explanation, the average juror might be unduly skeptical that a look, footstep, or tone of voice could in fact signal impending grave harm or that a reasonable person would be able accurately to assess the need to take self-defensive action on that basis. (State v. Kelly, supra, 478 A.2d at p. 378.) Accordingly, the trial court erred in categorically precluding consideration of evidence relevant to this purpose rather than giving a properly worded limiting instruction.

Prejudice

Notwithstanding the error, the question of prejudice is extremely close given the “miscarriage of justice” standard of review. (People v. Watson (1956) 46 Cal.2d 818, 836 [299 P.2d 243].) The faulty instruction precluded the jury from considering BWS in assessing defendant’s objective reasonableness. But such evidence could not be considered in a vacuum; it was relevant only to the extent it shed light on the reality of her perceptions. The pertinent inquiry therefore is whether the jury would have discounted any of defendant’s testimony in the absence of expert BWS evidence explaining it in that context.

As previously recounted, although defendant in many respects presented a traditional claim of self-defense independent of BWS, she also testified to circumstances that but for such evidence might not appear relevant to the objective component. Impliedly directed to disregard Bowker’s testimony that a battered woman “becomes sensitive to the abuser’s behavior,” the jury might not consider whether a reasonable person in defendant’s position would have perceived from Hampton’s “very, very heavy” walk or his “crazy” look an imminent attack or the need to react with deadly force. While not emphasizing the erroneous instruction, the prosecutor did note it to the jury. He argued defendant did not react reasonably by grabbing the gun in response to Hampton’s “[t]his time” threat because the remark was “like so many threats before” and could not be taken seriously, and she had *1103no reason to feel threatened “once she got the gun.” The prosecutor also questioned whether defendant could detect any difference in Hampton’s walk.

Other considerations tend to negate prejudice. Defendant made several inconsistent statements to the police shortly after the shooting that undermined her defense. In arguing against a finding of self-defense, the prosecutor did not substantially exploit any circumstances that hypervigilance would have explained as reasonable. Moreover, the instructions included CALJIC No. 5.50 (5th ed. 1988 bound vol.),1 which afforded an adequate basis for finding self-defense if the jury believed defendant’s account.

On balance, however, the scales tip marginally in defendant’s favor in light of her limited burden of proof. Defendant does not have to prove the homicide was justified; she merely has to raise a reasonable doubt that it might have been. (People v. Pineiro (1982) 129 Cal.App.3d 915, 921 [179 Cal.Rptr. 883]; People v. Banks (1976) 67 Cal.App.3d 379, 384 [137 Cal.Rptr. 652]; CALJIC No. 5.15.)

George, C. J., and Baxter, J., concurred.

CALJIC No. 5.50 provides: “A person threatened with an attack that justifies the exercise of the right of self-defense need not retreat. In the exercise of [her] right of self-defense such person may stand [her] ground and defend [herself] by the use of all force and means which would appear to be necessary to a reasonable person in a similar situation and with similar knowledge; and such person may pursue such assailant until [she] has secured [herself] from the danger if that course likewise appears reasonably necessary. This law applies even though the assailed person might more easily have gained safety by flight or by withdrawing from the scene.”

Defendant failed to request CALJIC No. 5.51 (5th ed. 1988 bound vol.): “Actual danger is not necessary to justify self-defense. If one is confronted by the appearance of danger which arouses in [his] [her] mind, as a reasonable person, an honest conviction and fear that [he] [she] is about to suffer bodily injury, and if a reasonable person in a like situation, seeing and knowing the same facts, would be justified in believing [himself] [herself] in like danger, and if that individual so confronted acts in self-defense upon such appearances and from such fear and honest convictions, such person’s right of self-defense is the same whether such danger is real or merely apparent.” Nor did she ask for an instruction explaining that threats may justify the defendant “in acting more quickly and taking harsher measures for her own protection in the event of assault, whether actual or threatened, than would a person who had not received such threats.” (People v. Bush, supra, 84 Cal.App.3d at p. 303.)