Someone can use deadly force in self-defense only if they truly believe it's necessary and a reasonable person in their situation would also believe that, not just whatever the shooter personally thought was fine.
Facts
Bernhard Goetz shot four young men on a subway after one asked him for money. He later told police he meant to hurt them and wished he had more bullets.
Procedural history
A grand jury charged Goetz with attempted murder and other crimes. Lower courts dismissed the charges, saying the prosecutor gave wrong self-defense instructions. The state appealed to New York's highest court.
Issue
Does the self-defense law require only that the shooter personally believed deadly force was necessary, or must that belief also be one a reasonable person would have had in the same situation?
Holding
The shooter must honestly believe deadly force is necessary, and that belief must also be reasonable. The prosecutor's instructions were correct, so the charges are reinstated.
Reasoning
New York's self-defense laws have always required reasonableness, not just personal belief. Allowing a purely personal standard would excuse people merely for claiming they felt justified, even irrationally.
Opinions
Majority (Wachtler, C.J.): Self-defense requires both an honest personal belief in the need for deadly force and an objectively reasonable belief, so the charges must be reinstated.
Test yourself
Question 1 of 5
What triggered Goetz's decision to open fire on the subway?
The opinion states Canty approached and said 'give me five dollars,' and that none of the youths displayed a weapon, though two had concealed screwdrivers Goetz was unaware of.
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On the exam
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Other issues in this opinion
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