State v. Benson
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The Supreme Court reversed the judgment of the Court of Criminal Appeals reversing Defendant's conviction of first-degree premeditated murder and remanding the case for a new trial, holding that the proof at trial did not fairly raise the issue of whether or not Defendant killed the victim in self-defense, and therefore, the trial court properly exercised its gate-keeping role in refusing to charge the jury on self-defense.
In reversing Defendant's conviction, the Court of Criminal Appeals held that self-defense should have been charged and that the error was not harmless. The Supreme Court reversed, holding (1) it is the role of the trial court to make a threshold determination of whether self-defense has been fairly raised by the evidence and thus should be submitted to the jury; (2) the trial court correctly concluded that the evidence in this case did not fairly raise as an issue that Defendant reasonably feared imminent death or serious bodily injury to justify his use of deadly force; and (3) therefore, the trial court properly refused to instruct the jury regarding self-defense.
Court Description:
Authoring Judge: Justice Roger A. Page
Trial Court Judge: Judge Lee V. Coffee
The defendant, Antonio Benson, was convicted of first-degree premeditated murder and sentenced to life in prison. On appeal, the defendant contended that the proof at trial fairly raised the issue of whether or not he killed the victim in self-defense and that the trial court erred in refusing to instruct the jury on self-defense. The Court of Criminal Appeals agreed that self-defense should have been charged and concluded that the error was not harmless. The intermediate court therefore reversed the defendant’s conviction and remanded the case for a new trial. We granted this appeal to clarify the gatekeeping function of a trial court when assessing whether self-defense has been fairly raised by the proof and to consider the quantum of proof necessary for a court to charge a jury on selfdefense. We hold that self-defense was not fairly raised by the proof in this case because the defendant was not lawfully defending himself when he killed the victim. We, therefore, reverse the judgment of the Court of Criminal Appeals.
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