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New York Court of Appeals - 68 N.Y.2d 96
Tags: Criminal law, Justification, Self-defense
tl;dr:
Reasonableness is required for the self-defense justification, even if the defendant sincerely believed that the force was necessary.Video Summary
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Bernhard Goetz was charged with attempted murder, assault, and possession of weapons after shooting and injuring four youths on a subway train in New York City. The court established that a claim of self-defense requires an objective element of reasonableness. The appropriate test for determining whether a defendant's use of force was justified is whether a reasonable person in the defendant's situation would have believed that the use of force was necessary. The court granted Goetz's motion to dismiss some of the charges but disagreed with dismissing all of them due to the introduction of an objective element or the perjured testimony of two key witnesses. The court held that a trial was necessary to determine whether Goetz's actions were reasonable given the perceived threat, as there was other evidence before the Grand Jury, including Goetz's own statements and the testimony of the passengers, which supported the charges. The higher court reversed the lower court's decision and reinstated the charges.
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