People v. Goetz

Criminal Law October 18th, 2020 People V. Goetz Facts: The victims, Troy Canty , Darryl Cabey , James Ramseur, and Barry Allen and the Defendant were traveling on a subway train in New York City. Canty approached the Defendant, possibly with Allen beside him, and said, “give me five dollars.” None of the youths displayed a weapon. The Defendant responded by standing up and firing four shots from his unlicensed .38 caliber pistol in rapid succession. A bullet struck each victim and the Defendant then shot Cabey again. Cabey’s spinal cord was severed in the attack, and he was paralyzed. The others fully recovered. The Defendant claimed that he was certain that the youths did not have guns, but he was afraid, based on prior experiences, of being “maimed.” Issue: Is the reasonable belief that a person is in imminent danger of death or serious bodily injury requirement for self-defense a wholly subjective test that focuses solely on the Defendant’s state of mind? Holding: No. Allowing a person to justify his conduct by self-defense simply because he personally believes that his actions are justified cannot be a result the legislature intended. This would allow any person, no matter how delusional, to kill at will if he believes his actions are justified. Therefore, “reasonableness” must be determined based upon the circumstances facing a defendant. Reasoning: In order for the defendant to use deadly force, he must reasonably believe that said force is necessary to prevent harm. This reasonable belief cannot be based upon his own thinking under the circumstances, but rather, what the circumstances dictate to a reasonable person. In other words, the court applied an objective standard. Concurring Opinion: The use of an entirely subjective test to determine whether a defendant appropriately used deadly physical force would be very dangerous, in that it would permit a jury to acquit every defendant who believed that his actions were reasonable, regardless of how bizarre the rationale. Dissenting Opinion: Court held that there was no basis for the lower court to suspect perjury, and that there was no basis in statute or case law permitting a dismissal merely because new information comes to light which may lead a defendant's acquittal. Your Thoughts: I believe there was no justification in this circumstance caused by the defendant. There was personal injury and a slew of everlasting damage with no justification on if there was a weapon or a reason to fear for your life. Also, the gun was unregistered so the defendant should be at fault for every injury caused, along with a gun charge.