People v. Goetz, 67 N.Y.2d 953 (1986)
r
r
The proper standard for determining whether a defendant’s conduct is justified under Penal Law article 35 is whether a reasonable person in the defendant’s situation would have believed that the use of deadly force was necessary to avert the imminent use of deadly force against them; the subjective belief of the defendant is not the sole determining factor.
r
r
Summary
r
This case addresses the standard for self-defense in New York. Bernhard Goetz shot four young men on a subway train, claiming self-defense. The Court of Appeals reversed the dismissal of attempted murder charges, clarifying that the justification defense requires an objective assessment of reasonableness, not just the defendant’s subjective belief. The Court held that a jury must consider whether a reasonable person in Goetz’s situation would have believed deadly force was necessary. This decision shifted the focus from Goetz’s state of mind to what a reasonable person would have done, setting a key precedent for self-defense claims in New York.
r
r
Facts
r
On December 22, 1984, Bernhard Goetz was on a New York City subway when four young men approached him. One of the men allegedly asked Goetz for five dollars. Goetz, who had been previously mugged, pulled out an unlicensed handgun and shot all four men. After the shooting, Goetz fled the scene but later turned himself in to police in New Hampshire. Goetz made statements to the police admitting to the shooting, claiming he felt threatened and acted in self-defense. The four men shot had screwdrivers, but these were not displayed during the encounter.
r
r
Procedural History
r
Goetz was indicted on several charges, including attempted murder. The trial court dismissed the attempted murder charges, finding that the prosecutor had improperly instructed the grand jury on the standard for self-defense. The Appellate Division affirmed. The Court of Appeals reversed the Appellate Division’s order, reinstating the attempted murder charges. The Court held that the justification defense in New York requires an objective element: a reasonable person standard.
r
r
Issue(s)
r
Whether the justification defense under New York Penal Law § 35.15 requires a purely subjective belief by the defendant that their use of deadly force was necessary, or whether it also requires an objective assessment of whether a reasonable person in the defendant’s situation would have believed that deadly force was necessary.
r
r
Holding
r
No, because New York’s justification statute requires an objective element. A jury must consider whether a reasonable person in the defendant’s situation would have believed that the use of deadly force was necessary to avert the imminent use of deadly force against them. The statute requires that the defendant “reasonably believes” deadly physical force is necessary. This imposes an objective element to any claim of self-defense.
r
r
Court’s Reasoning
r
The Court of Appeals analyzed Penal Law § 35.15, which outlines the defense of justification. The court emphasized that the statute uses the term