People v. Goetz

New York Court of Appeals (1986)

Defendant: Goetz; the defendant was riding in a New York subway and he felt that four teens were planning to rob him. Two of the teens came up to the defendant and asked him for $5. Goetz got up and started firing at the teens. He shot the teens while they were trying to escape. At the Grand Jury, the prosecutor argued that in order for the defendant to justify his actions under self-defense, he must show that his actions were objectively reasonable. The lower court rejected this arguemtn and the charges against the defendant were dropped and now the state appeals.

Issue: Does a defendant need objectively reasonable belief of immediate threat for him to use self-defense as a justification for his actions?

Holding: Yes

Key Facts: At the police station, the defendant admitted that he was robbed before and now he felt that the teens were going to rob him again. He also admitted that if he had more bullets, he was going to shoot the teens again and again.

Legal Reasoning: The court ruled that a reasonable man standard applies to self-defense cases. The court argued that if it accepts the subjective standard good enough to relieve the defendant of the liability, it would "allow citizens to set thier own standards for the permissible use of force..." So the court stated that in order for a person to use self-defense as a defense, he must prove to the jury that a reasonable person would have acted in the same way as he acted under the same conditions. So the charges were reinstated and it was left up to the jury to decide whether defendant met the reasonable person standards.

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