People v. Goetz

Brief Fact Summary. The Defendant, Bernhard Goetz (Defendant) shot and wounded four youths he believed to be trying to “play with” him.

Synopsis of Rule of Law. A person may use deadly force in self-defense if he reasonably believes that said force is necessary to protect himself.

Facts. The victims, Troy Canty (Canty), Darryl Cabey (Cabey), James Ramseur (Ramseur), and Barry Allen (Allen) and the Defendant were traveling on a subway train in New York City. Canty approached the Defendant, possibly with Allen beside him, and said, “give me five dollars.” None of the youths displayed a weapon. The Defendant responded by standing up and firing four shots from his unlicensed .38 caliber pistol in rapid succession. A bullet struck each victim and the Defendant then shot Cabey again. Cabey’s spinal cord was severed in the attack, and he was paralyzed. The others fully recovered. The Defendant claimed that he was certain that the youths did not have guns, but he was afraid, based on prior experiences, of being “maimed.”

Issue. Is the reasonable belief that a person is in imminent danger of death or serious bodily injury requirement for self-defense a wholly subjective test that focuses solely on the Defendant’s state of mind?

Held. No. Allowing a person to justify his conduct by self-defense simply because he personally believes that his actions are justified cannot be a result the legislature intended. This would allow any person, no matter how delusional, to kill at will if he believes his actions are justified. Therefore, “reasonableness” must be determined based upon the circumstances facing a defendant.

Discussion. In order for the defendant to use deadly force, he must reasonably believe that said force is necessary to prevent harm. This reasonable belief cannot be based upon his own thinking under the circumstances, but rather, what the circumstances dictate to a reasonable person. In other words, the court applied an objective standard.