State v. Strye

A defendant does not need to admit to harmful acts in order for a jury to consider whether, if the defendant committed the alleged acts, that the defendant did so in self-defense.

Defendant appeals convictions for assault in the fourth degree and criminal mistreatment in the fourth degree. Defendant assigns error to the trial court’s decision to disallow Defendant the opportunity to assert a claim of self-defense. Defendant worked at a residential care facility and was attempting to place an autistic patient in the shower in order to calm her down. In an effort to stop the patient’s attempts at resisting, Defendant allegedly punched her in the head. Defendant sought to raise claims that the patient was the cause of her own injuries and also that Defendant was justified in using physical force against the patient because Defendant felt that he was in danger of imminent physical force. The lower court determined that Defendant could not raise self-defense without first admitting that he had caused the patient’s injuries. The Court held that there was evidence that the jury could have used to determine that Defendant’s act of moving his hand toward defendant’s face was an act of self-defense because of his testimony and the testimony of a coworker which described a physically aggressive altercation initiated by the patient wherein she was self-harming. Defendant did not lose the ability to claim self-defense when he refused to admit that he caused the harm to the patient. Reversed and remanded.