State v. Bryan
Although Connecticut General Statutes §53a-19 provides for two separate, but related, defensesself-defense and defense of othersthe Connecticut Supreme Court has interpreted this provision consistently without regard to the specific type of claim asserted thereunder. Following a jury trial, Courtney Bryan was convicted of first degree assault and attempt to commit assault. Bryan admitted to stabbing the victim, Abdelmoutalib Sofiane, but claimed self defense and defense of another, Farrah Lawrence. The court refused his request for jury instructions on defense of others, instructing on self defense alone. Bryan appealed. The Appellate Court reversed the judgment holding that the court's refusal to charge on defense of others was improper. The Supreme Court granted the state's petition for certification to appeal and reversed the Appellate Court's judgment. No evidence supported the defendant's contention that when he stabbed the victim, it was objectively reasonable for him to believe that it was necessary to do so to defend Lawrence. Adopting the version of the facts most favorable to the defendant, the jury could have concluded that the victim was a violent person who repeatedly threatened Lawrence and the defendant, destroyed Lawrence's property, broke into her home and stabbed himself before her. The defendant was aware of this violent history. Both he and Lawrence testified to fearing the victim. The jury could have credited the defendant's testimony that the victim brandished a gun and threatened to kill Lawrence before walking toward the school building she entered. This evidence, if credited, would have been more than sufficient for a reasonable jury to conclude that the defendant believed the victim represented a threat to Lawrence. However, both the victim and the defendant testified that the victim turned away from the building upon the defendant's approach, faced him and a struggle ensued. No evidence revealed Lawrence's location within the building. No evidence would permit a reasonable jury to infer that the victim was using or about to use deadly physical force against Lawrence without resort to impermissible speculation. Even if the jury concluded that the defendant believed that the victim represented an imminent threat to Lawrence when stabbing him, no reasonable jury could find the defendant's belief to be objectively reasonable. Thus, the trial court properly refused to instruct the jury on the defense.