United States v. Dingwall, No. 20-1394 (7th Cir. 2021)
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Dingwall was charged with three counts of robbery and three counts of brandishing a firearm during a crime of violence. She admits the robberies but claims she committed them under duress, in fear of brutal violence by her abusive boyfriend, Stanley. Dingwall sought a ruling on evidence to support her duress defense, including expert evidence on battering and its effects. The duress defense has two elements: reasonable fear of imminent death or serious injury, and the absence of reasonable, legal alternatives to committing the crime. The district court denied Dingwall’s motion. Dingwall then pleaded guilty, reserving her right to appeal the decision on the motion in limine.
The Seventh Circuit reversed, noting that the cases are close and difficult, often dividing appellate panels. “Dingwall surely faces challenges” Stanley was not physically present for any of the robberies, Dingwall actually held a gun, and there is a dispute about whether Stanley threatened harm if she did not commit these specific offenses. Those facts present questions for a jury; the immediate physical presence of the threat is not always essential to a duress defense. Expert evidence of battering and its effects may inform the jury how an objectively reasonable person under the defendant’s circumstances might behave.
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