Juarez-Martinez v. Deans

424 S.E.2d 154

 

RULE:

When there is evidence that a defendant acted in self-defense, the defendant is entitled to have the jury consider this evidence. However, the right of self-defense is only available to a person who is without fault, and if the person voluntarily enters into a fight, that person cannot invoke the doctrine of self-defense unless they first abandon the fight, withdraw from it and give notice to their adversary that they have done so.

FACTS:

Plaintiff worked as a farm worker for defendant, and lived on the farm as well. One day, defendant entered plaintiff's home with a steel-tractor hitch, angry that plaintiff was not working. Defendant then poured beer on plaintiff after defendant found plaintiff sleeping. A scuffle ensued, and plaintiff was badly injured after being struck repeatedly with the tractor pin. Plaintiff sued defendant for assault and battery. At trial, defendant asserted self-defense and brought a claim for assault against plaintiff. According to defendant, plaintiff had tried to grab defendant after defendant poured beer on plaintiff's face, and defendant struck plaintiff out of fear for his safety. The trial court granted a directed verdict in favor of plaintiff on the issue of self-defense and defendant's counterclaim for assault. Defendant appealed.

ISSUE:

Did the parties provide sufficient evidence to prosecute both sets of claims?

ANSWER:

Yes.

CONCLUSION:

The Court found that both parties provided sufficient evidence to support their claims. It found that summary judgment was proper with regard to the defendant's counterclaim because the evidence adequately established the existence of probable cause to bring the criminal assault action notwithstanding the employer's acquittal on the charges. It found that a prima facie case of probable cause was established because the magistrate made an independent determination that probable cause existed and issued a warrant for the defendant's arrest. Finally, the court concluded that the trial court properly directed a verdict for the plaintiff on the assault counterclaim because although the plaintiff retaliated against the defendant, he was entitled to do so in self-defense. Accordingly, the court affirmed the trial court.

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