United States v. Donzell Wayne Biggs, AKA Maynard Wayne Hurley
441 F.3d 1069, 2006 U.S. App. LEXIS 7902, 2006 WL 827314 (2006)
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Rule of Law:
A prima facie claim of self-defense requires a defendant to show a reasonable belief in the necessity of force and the use of proportional force; it does not require an additional showing that there were no reasonable alternatives to the use of force.
Facts:
- Donzell Wayne Biggs was a federal inmate serving a life sentence at Lompoc, United States Penitentiary.
- He was housed in an administrative segregation unit where inmates are confined to their cells for twenty-three hours a day.
- For one hour each day, four prisoners at a time were allowed into a recreation cage.
- Biggs alleged that he knew a fellow inmate, Michael Smith, had been trying to obtain a knife and had threatened him on the way to the cage.
- On April 26, 2001, while inside the recreation cage with Smith, Biggs attacked Smith with an 8-inch homemade knife.
- Biggs stabbed Smith in the arm and ear.
Procedural Posture:
- The United States charged Donzell Wayne Biggs in federal district court with assault with a dangerous weapon and possession of contraband in prison.
- Before trial, the district court granted a motion in limine precluding Biggs from presenting a self-defense claim to the jury.
- The district court's ruling was based on its conclusion that Biggs could not show he had no reasonable alternatives to the use of force.
- Following the ruling, Biggs entered a conditional guilty plea, reserving his right to appeal the court's preclusion of his defense.
- Biggs (appellant) appealed the district court's pretrial ruling to the United States Court of Appeals for the Ninth Circuit.
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Issue:
Does a prima facie claim of self-defense require a defendant to show that there were no reasonable alternatives to the use of force?
Opinions:
Majority - Beezer, J.
No. A prima facie claim of self-defense does not require a defendant to show there were no reasonable alternatives to the use of force. The two elements of self-defense are: (1) a reasonable belief that the use of force was necessary to defend against the immediate use of unlawful force, and (2) the use of no more force than was reasonably necessary under the circumstances. The court reasoned that requiring proof of no reasonable alternatives improperly conflates the defense of self-defense with other justification defenses like duress and necessity, which are more constrained and do require such a showing. The court explicitly rejected the Seventh Circuit's reasoning in United States v. Haynes, which merges these concepts.
Analysis:
This decision clarifies and narrows the elements of a self-defense claim within the Ninth Circuit, distinguishing it from the broader justification defenses of duress and necessity. By rejecting the reasoning of the Seventh and First Circuits, this case establishes a significant circuit split on whether a defendant must prove a lack of lawful alternatives to successfully raise a self-defense claim. This split means that the viability of a self-defense claim in federal court can now depend on the geographical location of the jurisdiction, potentially impacting trial strategy and plea bargaining in similar cases nationwide.
