United States v. LaFleur

Brief Fact Summary. Appellant was convicted of premeditated murder, kidnapping and robbery. Appellant argued he committed these crimes under duress from his cohort and that he should be entitled to jury instructions reflecting this argument.

Synopsis of Rule of Law. The defense of duress is not a valid defense against murder nor to mitigate murder to voluntary manslaughter.

Facts. Appellant LaFleur, along with one other Appellant approached Victim and made him drive off with them in his own car. Appellant and his cohort shot the victim several times and left him to die. Appellant was found guilty of premeditated murder, kidnapping, and robbery. Appellant argued that the court erred in instructing the jury on voluntary manslaughter in that he acted under duress.

Issue. Whether Appellant can successfully assert a defense of duress.

Held. Duress is not a valid defense to first-degree murder nor can it mitigate murder to voluntary manslaughter.
One who under the pressure of an unlawful threat from another human being to harm him commits what would otherwise be a crime may under some circumstances be justified in doing what did and not guilty of the crime in question.

The choice of evils rationale presumes that the threatened harm to a defendant is greater than the resulting harm from a defendant’s acts.

Discussion. The Court ruled that the value of two human lives cannot be measured against each other. Thus one person cannot justify the taking of another’s life using the defense of duress. The death of an innocent person is at least equal to the threat of death of the actor.