Justices Limit Mistaken-Belief Claim by Accused Rapists : Appeal: The state Supreme Court issues the ruling to clear up confusion over a 17-year-old jury instruction. A defendant had maintained that he erroneously thought his victim had consented to having sex.

The California Supreme Court issued a ruling Monday limiting the defense of accused rapists who claim they had a mistaken belief that their victims consented to sex.

In an effort to clear up confusion in the lower courts over a 17-year-old jury instruction in rape cases, the justices ruled that the mistaken-belief defense is warranted only when there is “equivocal conduct” on the part of the victim that could reasonably be construed as consent.

The court also held that the appearance of consent by a victim after a show of force by an accused rapist should not be considered a valid defense.

“No doubt it would offend modern sensibilities to allow a defendant to assert a claim of reasonable and good faith but mistaken belief in consent based on the victim’s behavior after the defendant had exercised or threatened” force, concluded a five-member majority of the court.

The decision stemmed from a 1989 case involving a homeless woman in San Francisco who spent several hours in the company of Wash Jones Williams, a volunteer and resident at a local homeless shelter.

According to the victim’s account, Williams bought her a meal and suggested going to a place where they could watch television. He took her to a hotel that rented rooms by the hour and got a room that had no television. She testified that he hit her and forced her to have intercourse.

In a strikingly different account, Williams testified that she initiated sex and afterward demanded $50, threatening to claim he had raped her. At that point, Williams testified, he struck her in anger.

Both the defense and prosecution requested a jury instruction requiring jurors to find Williams not guilty if he had a reasonable and good-faith belief that the woman voluntarily consented to engage in sexual intercourse, even if that belief was mistaken.

Since a 1975 case known as Mayberry, courts had frequently issued such an instruction in rape cases, in part because of uncertainty over how appellate courts would view its omission.

But in the Williams case, Superior Court Judge Timothy Reardon refused, and a state appellate court overturned the conviction on the grounds that the jury instruction had not been given.

The Supreme Court concluded that Reardon had acted properly and reinstated the finding of guilty. The high court ruled that the facts in the case--as related by either party--did not support the possibility that Williams had the mistaken belief that the woman had consented.

Such a jury instruction need be given only “whenever there is substantial evidence of equivocal conduct that could be reasonably and in good faith relied on to form a mistaken belief of consent,” the court ruled.

In a separate matter, the Supreme Court rejected a convicted murderer’s plea that he should be granted a new trial because the judge in his case locked the doors of the courtroom during the prosecution’s final arguments.

Eight news organizations, including the Hearst Corp. and the New York Times, had joined in arguing that Johnie Monroe Woodward was denied his right to a fair trial because latecomers were excluded during a crucial 90-minute portion of the proceedings.

The Supreme Court concluded that Contra Costa County Superior Court Judge Patricia Sepulveda did not properly notify Woodward’s lawyer of the closure, as required under court rules. But the high court also held that the error had no effect on the jury’s verdict and was not sufficient to warrant a new trial.