The California Supreme Court reversed a decision of the court of appeal. The court held that the circumstances surrounding an assailant’s single deadly blow to a victim’s head supporting a finding of implied malice murder.

Seth Cravens and Emery Kauanui got into an argument at a bar. They were asked to leave and Kauanui went home. Cravens and his friends followed. En route, Cravens urged Eric House to beat up Kauanui when they got to his house. When they arrived at Kauanui’s home, House attacked him outside. Witnesses testified that Cravens’s other friends might also have joined in the attack on Kauanui. Kauanui, who made no more than an unsuccessful attempt to fight back, finally freed himself. He staggered away, unsteady on his feet.