SALT LAKE CITY — The Utah Court of Appeals has vacated a manslaughter conviction and ordered a new trial for a Midvale man who shot and killed another man during a heated exchange that began with making fun of a car and continued into road rage.
Patrick Koaneil Brown admits that he shot and killed Darnell Brown, 39, on April 21, 2021, the judge’s opinion says, but he claims that he worked to deescalate the situation and when that did not work and Brown hit his car, “he felt he had no choice but to shoot.” The two men were not related.
A jury found Patrick Brown guilty of murder on Aug. 25, 2022, but they also determined he acted in “imperfect self-defense,” which reduced his conviction to manslaughter, a second-degree felony. Patrick Brown was also found guilty of three counts of felony discharge of a firearm, two first-degree felonies and one third-degree felony, along with possession of a firearm by a restricted person, a second-degree felony.
He was sentenced to two terms of one to 15 years for manslaughter and possession of a firearm as a restricted person, two terms of five years to life for felony discharge of a firearm, and one sentence of three to five years for the remaining count of felony discharge of a firearm. The last term was ordered to run consecutively, meaning he was ordered to spend at least eight years and up to life in prison. At this point, he has already served about four years of that sentence, including two years he was given credit for ahead of his sentence.
In his appeal of the conviction, Brown argued that a detective should not have been allowed to testify that Darnell Brown ramming into Patrick Brown’s car caused damage more similar to criminal mischief than aggravated assault — which was an explanation to the jury of why perfect self-defense, which is justified under Utah’s law, would not apply.
The appellate judges agreed that the detective should not have testified about legal conclusions and the testimony caused prejudice against Patrick Brown in his trial.
His case will now go back to 3rd District Judge Adam Mow for a new trial.
On the morning of his death, Darnell Brown was driving with his fiancee and two daughters while Patrick Brown was selling clothes in his car to Darnell Brown’s friend, according to the opinion.
Darnell Brown stopped to talk to his friend and began to make fun of Patrick Brown’s Range Rover. Darnell Brown’s fiancee reported that he wanted to fight Patrick Brown and got out of the car, leading Patrick Brown to get a gun from his car — leading Darnell Brown to be more willing to fight Patrick Brown, the opinion says.
Eventually, Patrick Brown got into his car and drove away, but Darnell Brown followed for several blocks while yelling, honking and trying to cause a fight, witnesses testified, until they arrived at a red light.
“Once stopped, (Patrick) Brown leaned out his window and said, ‘If you follow me for another block, I’m going to shoot you in front of your family.’ In response, (Darnell Brown) hit the gas and ‘rammed (into) the back of’ Brown’s vehicle,” the opinion says, citing court testimony.
Darnell Brown backed up, stopped and got out of his vehicle. Patrick Brown made a U-turn and drove toward Darnell Brown, who was now standing on the street. Patrick Brown told officers he came back to get Darnell Brown’s tag number because he had hit him.
Bystanders reported that Darnell Brown did not seem to be de-escalating the situation; he looked ready to fight.
The opinion said that as Patrick Brown drove past Darnell Brown, he slowed down and fired four shots out his window, hitting and killing Darnell Brown. He said later he thought Darnell Brown had a weapon and may have called someone else to help him fight.
“I got caught in the situation. I’m accepting responsibility. I ain’t acting like I’m innocent. I know what I did was wrong. I wasn’t tryin’ to kill him. I wasn’t trying to shoot him up there. But when he dumped out the truck, it scared me. I thought he had a weapon,” Patrick Brown said in a quote the judges included in their opinion.
He maintained at his trial that he acted in justified self-defense. The opinion said prosecutors used the testimony from the officer that the bump would not be considered aggravated assault in their closing arguments at least twice.
“In the context of this case, the admission of that testimony and the prosecutor’s overt emphasis on it prejudiced Brown and undermines our confidence in the verdict,” the judges ruled.
