Falconer v. Lane

At her state court trial for murder, Phyllis Falconer attempted to prove that she killed her husband only in self-defense. The jury was instructed to consider the lesser offense of voluntary manslaughter. The jury nonetheless convicted Mrs. Falconer of murder and she was sentenced to 24 years in prison. Following a series of appeals described below, her second collateral attack on her conviction prevailed in district court. United States ex rel. Falconer v. Lane, 720 F. Supp. 631 (N.D.Ill. 1989). Paralleling a holding of the Illinois Supreme Court in a separate case, the district court held that the petitioner was denied due process because the instructions given to the jury at trial allowed the jury to return a verdict of murder even if the jury made findings that should have resulted in a verdict of voluntary manslaughter. We agree that the instructions were constitutionally inadequate under the Fourteenth Amendments Due Process Clause and therefore affirm.