State v. Gounagias Case Brief Summary | Law Case Explained

State v. Gounagias | 153 P. 9 (1915)

Under common law, voluntary manslaughter is an intentional homicide in which the defendant’s malice is mitigated by passion and provocation. If a defendant is provoked and, after time and contemplation, becomes enraged and kills his provoker, did the defendant commit murder or manslaughter? This was the question in State v. Gounagias.

John Gounagias and his roommate, Dan George, both of whom were Greek, worked with other members of the Greek community at a Washington paper mill. On April nineteenth, nineteen fourteen, Gounagias and George were drinking beer together in the house they shared. Gounagias became incapacitated, and after making insulting comments about Gounagias and his wife, George raped Gounagias. The next day, Gounagias confronted George about the assault, but George laughed at him. George went on to tell several community members about the assault, even though Gounagias begged him not to tell anyone. The story spread, and over the next three weeks, people repeatedly tormented and ridiculed Gounagias about the assault.

On May sixth, nineteen fourteen, Gounagias went to a coffeehouse where a group of men taunted him and made suggestive gestures, causing him to fly into a rage and decide to kill George. By this time, Gounagias had moved to a different house. He went home and retrieved his gun, then walked to George’s house and shot George five times in the head while he slept.

Gounagias was charged with first-degree murder. He asserted the common-law defense of provocation and asked the court to allow the jury to hear mitigating evidence. The trial court denied Gounagias’s request and excluded the evidence. The jury didn’t hear that George had told other people about the rape, nor did it hear the substance of the taunts Gounagias received on the day of the killing. The court also excluded the testimony of an expert psychiatrist who concluded that Gounagias acted on an involuntary impulse triggered by memories stirred up when he was taunted at the coffeehouse. Gounagias was convicted of first-degree murder and appealed to the Washington Supreme Court.

#casebriefs #lawcases #casesummaries