Law Blog

By Michael C. McDonald, J.D. and Lonnie L. McDowell, Esq. – McDowell Defense

As reported by NBCLosAngeles.com, Ricardo Medina, Jr., 36, who starred in Power Rangers Samurai and as the red Power Ranger in Power Rangers Wild Force will not face charges after stabbing his roommate to death with, what else, a Samurai sword. (The reports don’t actually indicate is was a Samurai sword, but it was a sword held by a Samurai, right? No?)

It is not every day that we hear of death by way of a medieval weapon, so it is important that we break this down with a full analysis as to what happened and why this Samurai Ranger apparently broke no code, or law.

What Happened:
Reports from NBCLosAngeles.com as well as TMZ indicate that a fight broke out between Medina and his roommate, Joshua Sutter, also 36, at their home in Palmdale, CA. Besides not explaining why two 36-year-olds were still living together as roommates, the reports also do not indicate what the fight was about or any details about the physicality of the conflict. The reports do indicate, however, that Medina retreated to his bedroom during the fight, where he stayed with his girlfriend and door closed until Sutter forced his way into the bedroom. That is when Medina allegedly stabbed Sutter once in the abdomen with his sword.

Legal Possibilities for the Killing:
Under the law, any killing of one human by another human is a homicide. The law treats homicide in one of five ways: First Degree Murder, Second Degree Murder, Voluntary Manslaughter, Involuntary Manslaughter, or Justifiable Homicide.

First Degree Murder:
In order to find a defendant guilty of First Degree Murder, there must be proof that the defendant had specific intent to kill—that the killing was deliberate and premeditated. This means the prosecution must prove the defendant killed the victim in a calm, cool manner, and had time to reflect on the idea of killing the victim, even if only for an instant.

In this case, as in many cases in which a homicide victim dies during a mutual struggle (a fight), proving malice can be very difficult. When both the victim and defendant were physically attacking each other, it is difficult to find some evidence that the defendant premeditated the kill—that he had the actual intent to kill the victim then successfully acted on that intent after reflection. Although the reports are sparse on the details, the fact that Sutter forced his way into Medina’s room after Medina had retreated indicates Medina had no such intent or period of reflection.

Second Degree Murder:
Second Degree Murder is any murder that is not First Degree Murder, meaning any murder committed without premeditation and deliberation. It still requires malice aforethought—either an intent to kill, intent to inflict great bodily injury, or at least a reckless disregard for an unjustifiably high risk to human life.
In this case of the Red Ranger and his sword, it does not seem difficult to find the required malice aforethought. When someone stabs another person in the abdomen with a sword, it seems pretty clear he had either the intent to kill, an intent to inflict great bodily injury, or at very least a reckless disregard for an unjustifiably high risk to human life. Even with an indication of malice, however, there are factors that can make what would otherwise be Second Degree Murder a justifiable homicide, such as a killing in self-defense.

Voluntary Manslaughter:
Volutary Manslaughter is a homicide that would otherwise be a murder but for an adequate provocation. Such provocation to reduce murder to manslaughter is such that would arouse a sudden and intense passion in an ordinary person, that did in fact arouse such passion in the defendant, without sufficient time for the defendant to cool off, and the defendant in fact did not cool off between the provocation and the killing. One example of such provocation for Voluntary Manslaughter includes being threatened with deadly force.

California also recognizes another way what would otherwise be murder can be reduced to Voluntary Manslaughter: Imperfect Self-Defense. Imperfect Self-Defense occurs when a defendant commits a homicide with a genuine, but unreasonable, belief that it is necessary to kill the other person to protect himself against deadly force from that person.

The Red Power Ranger reports do not indicate whether Sutter had a weapon when he forced his way into Medina’s bedroom or if there was any other legitimate threat of deadly force. The facts seem to indicate, however, that unless Sutter did pose a legitimate threat to Medina’s life, Medina could at least be found to have committed Voluntary Manslaughter. Based on the fact that Medina faces no charges, however, police must have found indications that Sutter did pose a reasonable threat to at least inflict great bodily harm on Medina, justifying the sword stabbing.

Involuntary Manslaughter:
Involuntary Manslaughter is a homicide committed through criminal negligence. Negligence is not a measure of intent—one cannot intend to be negligent. What it amounts to is an inexcusable act of carelessness that results in the death of another. The facts of this case do not indicate Medina could be found guilty of homicide through negligence.

Justifiable Homicide:
And finally we arrive at what the authorities apparently believe happened when Red Ranger used his sword: a Justifiable Homicide. A homicide is found to be justifiable when done in an act of self-defense or defense of another. The self-defense or defense of another, however, must be legitimate for the homicide to be justifiable. This means that the person who commits the homicide must have a reasonable belief that the use of deadly force is necessary to protect himself or another from deadly force or great bodily injury.

It would be a lot easier in this case to determine whether or not Medina’s stabbing of his roommate was a legitimate act of self-defense with more details than the reports provide. There are indications, however, that indicate the stabbing just may have been a legitimate act of self-defense. Medina retreated during the fight—he went inside his room, door shut, with his girlfriend, and Sutter forced his way inside the room, apparently to continue the fight. Someone forcing his way into a bedroom, an area of apparent safety, for the purpose of a physical attack certainly justifies some form of physical self-defense. As long as the facts support a reasonable belief by Medina that deadly force was necessary to protect himself or his girlfriend from death or great bodily injury, he was within his rights to protect himself and his girlfriend with the deadly force he used when he stabbed Sutter in the abdomen.

Furthermore, the reports indicate that Medina called the police after the stabbing and waited for them to arrive—not the actions you would expect of someone who just committed a murder.

Apparently Medina’s training for his role as Power Ranger Samurai paid off: he knows how and when to use his sword.