Chadwick 1

Ember Chadwick
Ms. Moser
Period 3
2 May 2016
Mock Trial Write-Up
On the afternoon of September 30, 1999, Thomas Simpson was found dead at 4:55 p.m.
on the doorstep of his home. The two gunshot wounds in his head were put there by Dale
Reynolds, his stepson. In the case of Reynolds v. Washington, the jury found the defendant
guilty of murder in the second degree, and sentenced him to 10 years in prison. However, based
on the evidence provided by the court, Dale should have been convicted of 1st degree murder.
Not only did Dale shoot Simpson on sight, but he blatantly confessed to Jan Martinez the
morning of the shooting that he was planning on killing his stepfather, and had an entire day to
contemplate his plans. On multiple occasions, this evidence proves that this murder was
premeditated and was not committed in self-defense. In turn, this confirms the prosecutions
claim that Dale Reynolds is guilty of 1st degree murder.
Detective Nickie Loo found Simpson lying dead on his doorstep, with two gunshot
wounds in his head. She found him without any weapons in his possession, and with no signs of
a struggle at the scene of the crime. This evidence proves that Dale did not kill his stepfather in
self defense. Reynolds could not have been truly afraid of his life, for there was no evidence to
show that Simpson was attempting to harm his stepson in his final moments. There was no sign
of a fight, which means that Simpson did not try to kill Reynolds when he arrived home. In fact,
Simpson didnt even have the chance to make it inside before he was shot, as he was found by
the police on his doorstep, not in his house. In addition to these findings, Simpson was shot

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twice in the head, which suggests that Dale was shooting to kill, not simply shooting to subdue.
Reynolds didnt wait for his stepfather to make a move, he didnt need to wait for Simpson to
threaten him, because he had already decided to kill him many hours before.
Jan Martinez, Dales girlfriend and close friend of several years, testified that he told her
of his plans to kill his stepfather. On the morning of September 30, on her way to school, she
stopped by Dales house. She explained that He showed me a loaded shotgun he was going to
use to kill his stepfather. Dale Reynolds plainly confessed, on the morning of his stepfathers
death, that he was going to murder Thomas Simpson. This on its own is enough evidence to
show that this shooting was premeditated, as Dale literally explained to Jan that he had the
intention of shooting Simpson, well before any life-threatening confrontation between the two
could have occurred. Jans testimony proves that the defendant was planning on killing Thomas
Simpson, hours before the shooting transpired.
It is also made clear that Dale Reynolds spent an entire day at home before the shooting
took place. Dale was home, alone, from the time Jan left for school until his stepfather arrived
home. High school classes generally start around 8:00 a.m., so one could conclude that Jan left
Dales house around this time. Simpson was shot as soon as he stepped into the door, and the
fact that Dale still had a gun in his hand when Detective Nickie Loo arrived implies that he
called the police soon after the shooting. Detective Loo received a call informing her of the
shooting at 4:45 p.m., and by combining this with the other information found in this case, it can
be estimated that Dale had at least 8 hours to himself in his home. This would have given the
defendant a great deal of time to contemplate his plans to kill his father. He would have had
many chances to rethink his decision, to lock up the guns, and to take any other action. This

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evidence shows that the Dale Reynolds could not have simply acted in self-defense in response
to an immediate threat, as he had been planning this murder for hours on end.
Of course, there are other perspectives on the outcome of this case. Some people may
also disagree with the jurys verdict, but because they believed that the defendant was acting in
self-defense. The main argument from the defense was that Dale suffered from battered child
syndrome. Dr. Pat Carol explained that, the battered child defense allows jurors to evaluate the
state of mind of the child at the time of the act of killing by considering a pattern of abuse that
had altered the child's perception about whether s/he was in imminent danger at the time of the
act. However, while Dale has definitely suffered horrible abuse in his life, evidence suggests
that there was not imminent danger at the time of the shooting. In fact, Thomas Simpson was
killed on his doorstep, without a chance of even walking inside his own house before he was shot
by his stepson. The battered child defence does not apply to this case, because there was no
evidence presented to the effect that the defendant was in imminent danger when he shot
Simpson.
Dale Reynolds ought to have been convicted of first degree murder, rather than second
degree in this case. Firstly, there was no sign of a conflict at the scene of the crime, and Simpson
was found dead on the doorstep, not even able to walk into his house before he was shot in the
head twice. The defendant even explicitly told his girlfriend on the morning of the shooting that
he was planning on killing his stepfather, and showed her the gun he had taken. To further prove
that this shooting was premeditated, it should be noted that Reynolds was able to contemplate
killing Thomas Simpson for at least 8 hours while he was sitting alone at home. This evidence
proves that Simpson was not shot in self-defence, but instead that this was a murder that had
been planned out before it occurred. The jurys verdict was nearly correct, but not quite. The

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defendant should have been charged with murder in the first degree, because the prosecution
proved on multiple accounts that Dale Reynolds had committed premeditated murder.