How have medical records and statements been used to support a defendant's claim of self-defense?

Defendant introduced medical records documenting that, five days before the charged incident, he went to the emergency room and was treated for seven "puncture wounds," a laceration on his arm treated with one staple, and an "upper lip laceration" treated with a suture. Defendant had also told the officers he spoke to on the night of the stabbing that he had been recently stabbed, including in the arm. To the officers, however, defendant did not appear to be injured. On the basis of the medical records and his statements, defendant argues that the trial court erred in not (1) tailoring the standard CALCRIM 505 self-defense instruction to tell the jurors to consider what a "reasonable person" would believe in "the context of [defendant's] documented injuries" from five days earlier; and (2) giving jury instruction CALCRIM 3429 pertaining to persons with physical disabilities. We review these instructional errors de novo. (People v. Posey (2004) 32 Cal.4th 193, 218.)

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