Hazardous duty self defense
There are some very interesting discussions being generated as a result of the Robert Lawlor acquittal in Hartford last week: what does this say about the community, what does it mean for the future of the city, will the mistrust between residents of the city and the police ever subside, is Hartford really one city or does everyone view the North End as a cesspool? [Even I arose from my slumber to post.]
Now, thanks to an “opinion piece” in today’s Courant, add one more conversation to the list: should there be a special “law enforcement self defense” provision in our law? The piece is authored by former prosecutor John Massameno (who, you might recall, was the prosecutor who oversaw the conviction of now exonerated Miguel Roman). Also, CT lawyers, stop the eye-rolling.
The piece is titled “Don’t charge police over errors”, so you would be right to believe that he is arguing for immunity from prosecution, not just a more expansive doctrine of self-defense. Indeed, most of his “opinion” piece reads like that:
Police officers need our help. They must make split-second but accurate decisions about using deadly force to protect themselves or others from harm. Occasionally, an officer makes a mistake. Absent some aggravating factor, such as an improper motive, the law should not criminalize officers’ good-faith mistakes in judgment. Otherwise, how can we expect them to take decisive action to protect lives when their own could be destroyed by doing so?
Yes, very good. But the crux of his “opinion” is an amendment to the self-defense statute, which would ask the jury to consider the dangers faced by police officers in their day-to-day business:
It gives an officer a defense to a homicide or assault charge when, in the line of duty, he “[makes] a mistake in judgment concerning the imminent use of force against him or a third person.” It requires the trial judge to tell jurors that “in assessing the reasonableness of the physical force used by [the] officer and … [his] belief that physical force would be used against him or a third person, [they must] consider the [officer's] unique status in the enforcement of the law, his background and training in the assessment of and response to the likelihood that physical force will be used against him, and the greater likelihood that physical force will be used against [an officer] than against a person not engaged in the enforcement of the law.”
The law wouldn’t require the jury to believe the defense, so when there’s evidence of some improper motive, such as racial hatred, a conviction for murder is still possible.
I applaud the attempt at de-criminalizing all assaults by police officers unless there’s evidence of some vague “improper motive”. But I see some problems with it. First, I’m not sure that there is a greater likelihood that physical force will be used against an officer than a common criminal normal person. I’d like to see some statistics to back this up. The universe of assaults on individuals is very large. The universe of arrests by police officers is larger still. However, the number of cases involving assaults on officers is significantly smaller than either one of those. So, logically speaking, the chance of being assaulted by someone if you’re a normal person should be higher than the chance of being assaulted if you’re an officer.
[I do acknowledge the apparent flaw in my logic that a normal individual would not normally be in the confrontational position that officers find themselves in when they're making arrests or conducting an investigation, but then again, nobody goes around shooting random people willy-nilly. If that is a flaw in my logic, then that's a flaw in Massameno's logic as well and his proposal should be altered accordingly.]
I’m also unsure of scenarios that this “change” in the law would leave criminalized. He suggests racial hatred, but how difficult is that to prove? Additionally, there’s nothing in a proposal that permits a jury to “improper motive” as a reason to reject self-defense. Massameno’s mention of that is a nod to jury nullification. So, in essence, he’s suggesting a modification to the law that would preclude prosecution of officers who shoot at citizens.
Frankly, I have no problem with this idea. Just expand it to all people, not just police officers. Why is my drug lord client also not in a unique position of working in a danger-laden profession? What about my clients that grew up in, and still reside in rough neighborhoods? They’re liable to be robbed and shot at any point. Why shouldn’t this extend to them as well? After all, regular self-defense makes no distinction between those engaged in legal and illegal conduct.
Of course, I have no doubt that Massameno wouldn’t agree with me. [The rest of the post is a bit of a sidetrack, so skip to the comments if you don't care.]
Massameno seems to struggle mightily throughout this “opinion piece” with his advocacy for those that are, in every sense of the word, criminal defendants and those that he normally associates with that phrase. In essence, he’s making the “they’re one of us, not one of them” argument:
[This proposal] does recognize that, when police mistakenly kill or injure someone in the performance of their duties, they should not be treated as common criminals, unless, of course, they are.
I have absolutely no idea what that sentence means. It seems to be internally contradictory: either they made a mistake or not, in which case it shouldn’t matter if they’re a common criminal (whatever that means). Even if the dirtiest cop in the world mistakenly shoots someone in the performance of his duties, he should get the benefit of Massameno’s proposal. But I don’t think Massameno can bring himself to say it. He has to still hedge his bets on the off-chance that the cop is really, really bad. In which case, he’s “one of them”, or something.
Of course, Massameno seems to have forgotten that a successful self-defense claim doesn’t negate the fact that a crime was indeed committed, thus turning the actor into a “criminal”. It simply justifies that criminal act and permits the actor to be treated as if he committed no crime.
Ironically, in the early part of the “opinion piece”, Massameno goes on at length about an Officer Smith, who 10 years ago shot and killed some common thug, but someone had the nerve (the nerve!) to charge him with murder, “a Class A felony, punishable by up to 60 years in prison!” (Yes, that is a direct quote, exclamation and all.)
Although Smith was not convicted of murder, he was convicted of manslaughter and sentenced to six years in prison. The conviction was reversed on appeal. Just before his new trial, wanting to avoid prison, Smith felt compelled to accept a plea agreement that turned him into a convicted criminal.
Yet, what if Smith had lost his appeal? The original conviction would have been upheld and Smith’s life would have been destroyed. Given the publicity surrounding his trial, with civil rights advocates claiming that he shot Reid because he was black, Smith probably would have met a terrible end in prison at the hands of the type of criminals he had vowed to bring to justice.
But…but…I thought only guilty people pled guilty. What’s that? The Earth is not flat?
Anyway, as I said, I haven’t made up my mind either way on this proposal, or something like this. It’s just a discussion, after all. So what do you think, you-who-are-less-snarky-than-I? Should there be a special hazardous duty provision? Should it apply to everyone? Or is the law of self-defense fine just the way it is? If you like this post, you can bookmark it for later use.
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about 8 months ago
This is a complex area, but IMHO Massameno is completely wrong and may not understand the large body of research and law on the interrelationship between police use-of-force and ordinary self-defense.
The normal, ordinary rules of self-defense are perfectly adequate to deal with police use of force. The only normal distinctions are that police are not required to retreat before using force — which makes sense, otherwise they’d never make arrests. Similarly, police can use force to make an arrest or, in limited cases, for searches without becoming the first aggressor and being disqualified from self-defense.
The jury is going to hear about the officer’s training — that’s part of what makes his or her decision subjectively reasonable. A use-of-force/self-defense expert could also testify about perception, memory, reaction time, etc., in any self-defense case to explain what’s objectively reasonable.
The jury is going to hear about third-party self-defense, which again applies to police and the public alike. If we had a mall-shooter or school-shooter in CT, it shouldn’t matter whether the person stopping the maniac has a badge or not, and we really don’t want a public citizen stopping to think — will I get into trouble for saving lives.
If an ordinary citizen has to use force to defend himself or herself from a violent aggressor, they deserve deference to _reasonable_ split-second decisons. This is not a new idea — Justice Holmes wrote that “Detached reflection cannot be demanded in the presence of an uplifted knife.” back in Brown v. United States, 256 U.S. 335, 343 (1921).
What’s good for the goose is good for the gander and there is no reason to separate police from the public.
about 8 months ago
I knew someone would have an idea of the research out there.
I think all your points are very well taken: the fact that self-defense includes a subjective component as well as objective and both would cover the areas Massameno proposes for this special police instruction.
I think apart from the law, there are further societal implications of such a proposal: it further divides the police from the community they are charged with protecting and it may serve only to fuel the perception that one set of rules apply to cops and another to everyone else.
about 8 months ago
I think that, if anything, police officers have less excuse than ordinary citizens when they use deadly force in the mistaken belief that such force is necessary to prevent imminent bodily harm to themselves or others, because they are presumably trained to deal with such situations whereas ordinary citizens aren’t. A while back I described to a police officer friend the very scary scenario that had faced a client who was charged with attempted murder, hoping the police officer would confirm that if he had faced a similar scenario he would have been justified in shooting under his department’s policies. But he didn’t think he would be. He would have instead raised his gun, pointed it at the threat and ordered him to drop his weapon. But if I put myself in my client’s position, I think I would have reacted the way my client did rather than the way my police officer friend said he would. I’m not used to pointing a gun at another person and ordering them to drop their weapon. If I’m in enough fear for my life to point a gun at another person holding a gun, I’m likely to shoot and not wait for him to shoot me.
about 8 months ago
Training helps, but not as much as one might think. And good, realistic use of force or self-defense training is expensive and time consuming.
But key in this officer’s testmony would be questions about what training he received, the distances involved, and very fact-specific details about the aggressor/victim’s movements and actions. Were I thinking about questioning the officer in this way, I’d want to know about specific training in that department on reaction time.
Also remember that the officer on the stand has the benefit of hindsight, he knows if a weapon was found on the aggressor/victim and may know much more about that person than your client did.
Some interesting reading:
http://www.forcescience.org/articles/shotinback.pdf
Tobin & Fackler, Officer Reaction – Response Times in Firing a Handgun, 3:1 Wound Ballistic Rev.
http://www.forcescience.org/articles/tempestudy.pdf
http://www.forcescience.org/articles/tempestudy2.pdf
http://www.fbi.gov/publications/leb/2006/march2006/mar06leb.htm#page14
http://www.theppsc.org/Staff_Views/Tueller/How.Close.htm
AND
Violent Encounters: Felonious Assaults on America’s Law Enforcement Officers is available for free from the UCR Program Office, FBI Complex, 1000 Custer Hollow Road, Clarksburg, WV 26306-0150 or by calling 888-827-6427
about 8 months ago
Okay, this may be totally cynical and unfair, but this proposal seems to be a protection for prosecutors who are too scared to do the right thing. If a police officer is charged with assault or murder for shooting someone, and that officer has a good self-defense claim, doesn’t the prosecutor have the authority under the current law to drop the case or resolve it favorably for the officer? Why do we need a change in the law that casts such a wide net when we have prosecutors who should use their discretion and make individual determinations about whether a case should proceed/go to trial or not? Seems to me that this change in the law would be a disservice to our citizens (and to the police departments to the extent that relations further deteriorate with the community), doesn’t serve to protect our officers in the line of duty (would anyone seeking to hurt an officer be deterred by this law – aren’t these the situations in which the officer would be justified in using force anyway?!), and merely would ensure that prosecutors don’t have to make tough decisions and be in the hot seat. Sorry, but not enough to convince me.
about 8 months ago
If he wanted to help with those decisions, there is some good training available for prosecutors (which could also be done for defense attorneys) about use of force issues.
http://www.fbi.gov/publications/leb/2009/april2009/law_enforcement.htm
about 8 months ago
Reading this, two words sprang to mind: Cory Maye.
Maye shot a guy breaking into his child’s bedroom. It turns out the guy was a cop trying to serve a warrant on the adjacent apartment. Maye was sentenced to death.
I wonder if Massameno believes Maye deserved a split-second error exception for shooting the cop?
about 8 months ago
Fortunately he got a new trial on appeal
about 8 months ago
Indeed he did, which is good news. But I’m curious if Massameno believes that guy defending his child against what appears to be a violent break-in also deserves the same exception. If not, why? Is parental instinct not as strong an influence on behavior as police training? Or if Maye does deserve the split-second exception, then why limit it only to the police? I don’t think Massameno can have a consistent response to this.
about 8 months ago
(Un)fortunately, I don’t think he will have any response.
about 8 months ago
It takes a pretty damn egregious set of circumstances for a police officer to be held accountable for the vast majority of these so-called reasonable use of force cases. An overwhelming number of such incidents are never charged in the first place. In rare cases where they are, amazingly, many coppers opt for a bench trial and are eventually acquitted, reinstated and receive back pay. In a recent case in my area, the police were raiding a bar allegedly involved in drug trafficking and on the way in one of them smashes a bystander (who by all accounts was doing nothing more than simply hanging out in front of the place), in the face with the butt of an assault rife. Waived a jury and the judge acquitted him of felonious assault. I think this is more representative of what typically happens when the system is confronted with such scenarios and evidences the fact that the police are certainly not in need of greater protections, but, indeed, fewer. While hesitant (only a little) to paint all law enforcement officers with a broad brush, the fact of the matter remains that way too many cops enter the field with a bully mentality…
about 8 months ago
I haven’t heard of many cops opting for a bench trial. In these parts, if memory serves me right, most recent cop shooting trials have been tried to a jury. Can’t remember the last time one was convicted, though.