Case Explained: United States v. Lynn

Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-06-30 Docket: 4:24-CR-00076-GKF-1) The Tenth Circuit affirmed the defendant’s convictions on counts involving assault and firearm use but reversed his first-degree murder conviction due to a jury instruction error. The court held that the district court did not abuse its discretion in admitting a tribal database screenshot under the business records exception (Fed. R. Evid. 803(6)) and found no Confrontation Clause violation, as the record was non-testimonial and contained verified information from an outside source. Regarding jury instructions, the court rejected the defendant’s claim that adding language about the duty to retreat to the perfect self-defense instruction was erroneous. However, the court agreed with the defendant that the district court committed reversible error by failing to instruct the jury that the government must disprove imperfect self-defense beyond a reasonable doubt. Citing *United States v. Maryboy*, 138 F.4th 1274 (10th Cir. 2025), the court ruled that because imperfect self-defense negates the malice element required for murder, the government bears the burden of disproving it beyond a reasonable doubt. The court determined this error was not harmless beyond a reasonable doubt because the district court had already ruled there was sufficient evidence to warrant an imperfect self-defense instruction, and the jury structure precluded them from considering its effect on the murder charge. Consequently, the court remanded with instructions to vacate the first-degree murder conviction while affirming the remaining convictions. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.