State v. Sorbonne
State v. Sorbonne, 2022 UT 5 (Lee J., majority)
Defendant was charged and convicted on a misdemeanor charge of threatening to use a dangerous weapon during an argument with Father. Defendant brought a self-defense argument, highlighting Father’s history of violent behavior, and Defendant’s belief that his actions were necessary to defend himself under the circumstances. The court admitted some, but not all, of the evidence of Father’s violent behavior, and it found Defendant guilty. The court of appeals affirmed. On certiorari, the Utah Supreme Court affirmed:
- An individual is “justified” in “threatening or using force” against another if and where he “reasonably believes” such force is necessary. Utah Code § 76-2-402(2)(a). This standard encompasses both a subjective and an objective component. “[T]he assessment of an individual’s reasonable belief should be undertaken in light of all relevant circumstances, including any past pattern or history of abuse (as with ‘battered spouse syndrome’).” The court of appeals’ ruling comported with these principles.