Brief Fact Summary. The Defendant, Yvonne Wanrow (Defendant), shot and killed William Wesler (Wesler) in a startled reaction to turning around and finding Wesler, a large, visibly intoxicated man, standing behind her.
Synopsis of Rule of Law. The reasonableness of a person’s actions in self-defense must be considered in the light of her own perceptions of the situation.
Issue. Should consideration be given to a person’s own perceptions of the situation when evaluating whether the person reasonably believed that deadly force was necessary in the interest of self-defense?
Held. Yes. The justification of self-defense is to be evaluated in light of all the facts and circumstances known to the defendant, including those known substantially before the killing. Further, a defendant’s own perceptions of the situation are integral to making a determination of whether she properly acted in self-defense in accordance with those perceptions. Since the Defendant was a diminutive woman with a cast on her leg and the victim was a large, intoxicated man, due consideration must be given to the difficulty she would have had in repelling him without the use of weapons in her defense.
Discussion. Self-defense instructions must take into account that women are generally smaller and not as physically strong as men are. Hence, their perceptions of the situation will generally be different than a man’s perceptions.