People v. Salas

Defendant, age 16 at time of offense, was convicted of first-degree murder and sentenced to 50 years imprisonment. Automatic transfer statute, by which 15- and 16-year olds accused of first-degree murder are automatically tried as adults, does not violate substantive or procedural due process. Court, which instructed jury on self-defense, did not abuse its discretion by failing to also instruct jury on second-degree murder or involuntary manslaughter, as evidence did not support self-defense instruction or recklessness in shooting. (HALL and KARNEZIS, concurring.)