United States v. Taylor, No. 11-2875 (3d Cir. 2012)
Annotate this CaseAfter guard mistakenly gave Taylor, an inmate convicted of drug and weapons charges, an extra razor blade, Taylor created a shank. Subsequently, in an exercise yard with Bistrain, Taylor construed Bistrain’s comment as a threat. After Bistrian was handcuffed, Taylor, not yet handcuffed, slashed his face, arms, and legs with the shank. Guards used pepper spray but did not subdue Taylor until they tossed a flash grenade into the yard. Taylor told guards that he had to get Bistrian before Bistrian got him. Taylor was convicted of assault with a dangerous weapon, 18 U.S.C. 113(a)(3) and sentenced to an additional 120 months. Taylor attempted to show justification and claimed that the prosecution was racially motivated because he was charged for this assault, on a white victim, but had not been charged for an earlier assault on black inmates. The Third Circuit affirmed. By including “without just cause or excuse” in the statute Congress did not intend to convert justification, a common-law defense, into an element for which the government bears the burden of proof beyond a reasonable doubt. Just cause is an affirmative defense to a section 113(a)(3) violation; defendant bears the burden of proving it by a preponderance of the evidence.
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