The primary issue in this appeal concerns the applicability of self-defense to all categories of homicide. The court reaffirms the well-settled principle that self-defense, once found by a jury, shall serve as a complete justification for murder as well as all manslaughter offenses charged or otherwise permitted for consideration as lesser-included offenses.
Here, the jury found defendant met the self-defense test for murder but not passion/provocation manslaughter, returning a guilty verdict for the latter offense. Based on that facially inconsistent verdict, our jurisprudence, and the established precept that self-defense is a complete defense to all categories of homicide, the court reverses defendant's conviction for passion/provocation manslaughter.
In the unpublished portion of this opinion, the court addresses defendant's remaining arguments, including the trial court declining to charge aggravated assault, the applicability of self-defense to the weapons charges, the value of Rios's vehicle as it relates to the theft charge, and a review of the sentence imposed, respectively. These arguments are largely rendered moot, affirmed, or remanded for resentencing.