Graves v. United States
1989 WL 19023, 1989 D.C. App. LEXIS 37, 554 A.2d 1145 (1989)
Rule of Law:
A defendant is entitled to a jury instruction on the defense of others if there is any evidence, however weak, to support a reasonable belief by the intervenor that a third person was in imminent danger of serious bodily harm, and the force used was not excessive as a matter of law.
Facts:
- On the evening of October 1, 1983, Willie Witherspoon came to the Graves' apartment complex looking for his girlfriend, Geneva Truitt.
- Edmond Graves initially denied knowing Truitt's whereabouts, though she was upstairs socializing with his pregnant wife, Sheila Graves.
- Witherspoon found Truitt upstairs and requested she accompany him home, but she expressed a desire to stay.
- As Witherspoon was leaving, he again encountered Graves and demanded to know why Graves had not told him Truitt was upstairs, leading to an argument.
- Sheila Graves, who was over eight months pregnant and diabetic, and Geneva Truitt came downstairs after hearing the commotion.
- Witness accounts varied, but some suggested Witherspoon lunged at Graves while Sheila Graves was standing nearby, prompting her to call out to her husband to 'look out' or 'watch his back'.
- Edmond Graves, who was unusually worried about the health of his wife and unborn child due to her pregnancy, diabetes, and their history of a handicapped child, stabbed Witherspoon once in the chest, resulting in Witherspoon's death.
Procedural Posture:
- Edmond Graves was convicted in a trial court of second-degree murder while armed and carrying a dangerous weapon.
- Graves appealed his conviction for second-degree murder to the District of Columbia Court of Appeals, arguing the trial court erred by refusing to instruct the jury on defense of others.
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Issue:
Did the trial court commit reversible error by refusing to instruct the jury on the defense of others, despite some evidence supporting Edmond Graves' reasonable belief that his pregnant wife was in imminent danger of serious bodily harm during an altercation?
Opinions:
Majority - Newman, Associate Judge
Yes, the trial court committed reversible error by refusing to instruct the jury on the defense of others, as there was sufficient evidence to support Edmond Graves' reasonable belief that his pregnant wife was in imminent danger. The court emphasized that a defendant is entitled to a jury instruction on a theory of the case that negates guilt if it is supported by 'any evidence, however weak.' This standard applies to the defense of third persons, where the intervenor is entitled to use reasonable force based on the facts as the intervenor, not the victim, reasonably perceives them. Testimony from various witnesses regarding Sheila Graves' proximity to the altercation, combined with evidence of her advanced pregnancy and Graves' heightened concern for her and their unborn child, could allow a reasonable juror to infer that Graves reasonably believed his wife and unborn child were in danger. Furthermore, the court found it could not say as a matter of law that a single stab wound was excessive force, indicating this was a factual determination for a properly instructed jury, especially given Graves' raised position on the stoop and his belief in imminent danger to his nearby wife, thereby reversing the murder conviction.
Analysis:
This case significantly clarifies the low threshold for requiring a jury instruction on the defense of others, reaffirming that a defendant needs to present only 'any evidence, however weak,' to be entitled to such an instruction. It underscores that the intervenor's subjective, yet objectively reasonable, perception of the threat is central to this defense, rather than the victim's perception or the actual intent of the aggressor. The ruling also reinforces the principle that whether the force used was excessive is generally a question of fact for the jury, preventing courts from summarily dismissing the defense unless the force is undeniably disproportionate as a matter of law. This decision ensures that defendants have a full opportunity to present their theory of defense to the jury when supported by minimal evidence, impacting how trial courts assess requests for jury instructions in self-defense and defense of others cases.
