People v. Bates

Defendant David Richard Bates shot M.H. in the head, killing him. A jury found him guilty of voluntary manslaughter and the court sentenced him to 18 years in state prison.

On appeal, defendant contends the trial court erred in refusing his request to instruct the jury regarding the effect of the victim's past harmful or threatening conduct on the reasonableness of a defendant's belief in the need for self-defense. He also challenges imposition of a five-year prior serious felony enhancement under Penal Code section 667, subdivision (a)(1)1 on several grounds, including that the sentence was…