Tatman v. Cordingly
672 P.2d 1286 (1983)
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Rule of Law:
A claim of self-defense against a battery charge is justified if the defendant honestly and reasonably believed force was necessary to repel an attack, and the amount of force used was no more than what a reasonably prudent person would have used under similar circumstances.
Facts:
- A dispute existed between E. Ben Tatman, 66, and Gary L. Cordingly, who was in his early 20s.
- The two men had a confrontation on June 1, 1982, in a remote area in Albany County.
- According to Cordingly, Tatman ran over Cordingly's motorcycle with his pickup truck.
- Cordingly testified that Tatman struck him first during the altercation.
- Cordingly also stated that Tatman repeatedly tried to access a rifle in his truck, causing Cordingly to fear for his life.
- Cordingly struck Tatman multiple times, leading to Tatman's hospitalization for eight days with substantial medical expenses.
- Cordingly was uninjured in the fight.
Procedural Posture:
- E. Ben Tatman sued Gary L. Cordingly in a trial court for assault and battery.
- The case was tried before a jury.
- The jury returned a special verdict finding that Tatman had committed a battery and that Cordingly had exercised reasonable self-defense.
- The trial court entered judgment in favor of Cordingly.
- Tatman, as appellant, appealed the judgment to the Supreme Court of Wyoming, with Cordingly as the appellee.
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Issue:
Does a defendant act in lawful self-defense when they use significant force against an aggressor, resulting in severe injuries, if the defendant honestly and reasonably believes such force is necessary to prevent imminent harm?
Opinions:
Majority - Brown, Justice
Yes. A defendant acts in lawful self-defense when they use force that is reasonably proportional to an honestly and reasonably perceived threat. The court deferred to the jury's findings of fact, which accepted Cordingly's testimony that Tatman was the aggressor, struck first, and attempted to get a rifle. Given these circumstances, the jury was entitled to conclude that Cordingly honestly and reasonably feared for his life and that the force he used was what a prudent person would deem necessary to repel the threat, despite the resulting disparity in injuries. The court also held that while one jury instruction was technically incomplete, the instructions as a whole accurately conveyed the law on self-defense, rendering the error harmless.
Analysis:
This decision reaffirms the dual subjective and objective standard for evaluating a self-defense claim in tort law. It underscores the high level of deference appellate courts grant to jury findings on credibility and fact, particularly in cases with conflicting testimony and no other witnesses. The case clarifies that a significant imbalance in injuries does not, by itself, defeat a claim of self-defense if the jury finds the defender's perception of the threat and the level of responsive force were both reasonable. This precedent reinforces that the context of the threat, including the presence of a weapon, is central to assessing the reasonableness of the defender's actions.
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