Brooks v. State
630 So. 2d 160 (1993)
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Rule of Law:
A claim of self-defense, even when supported by expert testimony on Battered Woman Syndrome, may be rejected by a jury if there is sufficient evidence to show the defendant could have avoided the use of deadly force by retreating to a place of complete safety.
Facts:
- Marguerite Louise Brooks had a long history of being physically abused by her husband, Lewis Brooks, as well as by a former husband and another male partner.
- On September 18, 1992, Lewis Brooks, who was drunk and angry, publicly accosted Marguerite Brooks while she was walking with her friend, Jeanette McLendon.
- Lewis Brooks grabbed Marguerite's blouse, cursed at her, and jerked her towards him before she pulled free.
- Marguerite and Ms. McLendon fled to Ms. McLendon's house, pursued by Lewis, who told a friend he was "going to kill that bitch."
- Inside the house, Marguerite stated she "wasn't going to come out that door empty-handed," retrieved a handgun from a dresser drawer, and went back outside.
- Marguerite confronted her husband, telling him to stay back and that she would shoot, but he continued to advance on her with his hands raised.
- As Lewis Brooks continued to approach, he told her, "You got the gun; go on and do what you got to do."
- Marguerite Brooks then shot and killed her husband.
Procedural Posture:
- The State of Alabama prosecuted Marguerite Louise Brooks for the murder of her husband in the circuit court (trial court).
- At trial, Brooks admitted to the killing but claimed self-defense, supported by expert testimony that she suffered from Battered Woman Syndrome.
- A jury found Brooks guilty of murder.
- The trial court sentenced Brooks to life imprisonment.
- Brooks filed a motion for judgment of acquittal and a motion for a new trial, both of which were denied by the trial court.
- Brooks, as the appellant, appealed her conviction to the Court of Criminal Appeals of Alabama, with the State as the appellee.
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Issue:
Is a jury's murder conviction against a defendant who presented substantial evidence of Battered Woman Syndrome and self-defense wrong as a matter of law when there was also evidence that the defendant could have safely retreated?
Opinions:
Majority - Presiding Judge Bowen
No. A jury's murder conviction is not wrong as a matter of law where there is evidence negating a necessary element of self-defense. Although the appellant presented evidence of Battered Woman Syndrome that could support an honest belief of imminent danger, there was also evidence from which the jury could have found she was not justified in using deadly force. Under Alabama Code § 13A-3-23(b)(1), a person has a duty to retreat if they can do so with complete safety. The jury could have concluded that the appellant could have avoided the necessity of using deadly force by simply remaining inside Ms. McLendon's house. The question of whether a killing is justified under a theory of self-defense is a matter for the jury to decide, and the jury has the discretion to accept or reject the defendant's evidence, even if it is undisputed. Therefore, the jury's verdict was supported by the evidence presented at trial.
Analysis:
This decision reaffirms the strict application of the duty to retreat in Alabama's self-defense law, even in the context of domestic abuse. The court clarifies that evidence of Battered Woman Syndrome does not create an exception to the retreat doctrine but is instead a factor for the jury to consider when evaluating the defendant's subjective belief of imminent danger. The ruling emphasizes that the objective possibility of a safe retreat can override a self-defense claim, placing a significant burden on defendants to prove no such avenue existed. This makes it more difficult for battered persons who kill their abusers to succeed with a self-defense claim if they had any opportunity to escape the immediate confrontation.
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