People v. La Voie

Brief Fact Summary.

La Voie (Defendant) shot and killed one of four men who were threatening him after running his vehicle off of the road.

Facts.

Defendant’s car was forced off the road by another vehicle while he was driving home from work early one morning. Four men got out of the other vehicle and began to threaten Defendant. The men approached Defendant and he pulled out a handgun and fatally shot one of the men. Defendant was tried for murder. Following the trial, the court directed a not guilty verdict and the State appealed.

Issue.

Is an individual in reasonable fear for his own safety justified in using deadly force against the threat?

Held.

(Moore, J.) Yes. An individual who is reasonably in fear for his own safety is justified in using deadly force against the threatening individual. A person who has reasonable grounds to believe, and who actually believes,that great bodily harm is imminent may defend himself. That defense justifiably includes the use of deadly force, so long as that force is not disproportionate to the threat. Here, Defendant was forced off the road and then threatened by four men who were approaching him. It was reasonable for Defendant to be in fear of imminent bodily harm and to protect himself. Affirmed

Discussion.

The principle of self-defense has a subjective and an objective requirement. An individual’s actual subjective fear for his safety must also be objectively reasonable. This objective requirement mirrors the “reasonable man” standard often used in tort law.