Friday, March 23, 2012

Trayvon Martin -- "Stand Your Ground" vs. "Pursue and Confront"

[Note: I've updated the discussion near the end of the post regarding burdens of proof]

There isn't much that hasn't already been said about the Trayvon Martin tragedy; at this point, even the president has weighed in. For the most part, people across the political spectrum agree that the situation should be investigated further, and it should go without saying that if George Zimmerman broke the law, he should bear the consequences.

But I want to use this post to explore the genesis of Florida's "stand your ground" law, and how that law might apply.

Let's start with the basics: historically, if you beat someone up, you were liable for battery. But you could avoid liability if were acting in self-defense -- the guy came after your first. For years, though, you would that defense if you have safely retreated from the fight. was the "duty to retreat" .

The duty to retreat itself had an exception: you did not have to retreat from, or within, your own home. So if someone broke into your house and threatened you, and you could safely retreat, you nonetheless did not have to do so; you could respond with force, up to and including deadly force. This was known as the "Castle doctrine", so called because "an Englishman's home is his castle". (Remember, most U.S. laws have their roots in English common law.)

So to recap: if you are attacked in public and can safely retreat, you must do so, but if you are attacked in your home, you can respond with deadly force, even if you can safely retreat. And that was the state of the law for hundreds of years.

But relatively recently -- first, about a hundred years ago, and then in the last ten or so years -- U.S. states have been expanding the Castle doctrine. Generally, people may respond with wherever they are. These statutes eliminate the common law duty to retreat. Florida has enacted such a law. The statute says, in relevant part, that someone "who is not engaged in an unlawful activity and who is attacked in any other place where he or she has a right to be has no duty to retreat". Fla. Stat. § 776.013(3).

How does that apply to Trayvon's case? (I'm assuming facts that closely to reasonable inferences that we can draw from the 911 recordings and other data, though it's important to note that we don't, and probably never will, know exactly what happened that night.)

So let's walk through the law. Obviously Zimmerman has killed Trayvon. Zimmerman will raise the defense of self-defense. The prosecutor will respond that he could and should have retreated; Zimmerman will point to Section 776.013.

Many commentators, including a sponsor of the original Florida law, have said that Section 776.013 does not give someone a right to "pursue and confront". But why not? After all, Zimmerman "ha[d] the right to be" in the gated community, and the law gives protection to someone in his vehicle. See Fla. Stat. § 776.013(1)(a).

I would focus, not on whether Zimmerman had a "right to be" in a particular area, but on two other things: first, whether was "engaged in unlawful activity" at the time of the attack, and second, whether Zimmerman "m[e]t force with force" .

Was Zimmerman engaged in unlawful activity? Trayvon's girlfriend says that she was talking to him just before the attack, and that Trayvon knew he was being followed and was trying to get away from Zimmerman. Reportedly, Zimmerman weighs 100 pounds more than Trayvon. If, by words or actions, Zimmerman created a "well-founded fear" in Trayvon and caused him to feel threatened, Zimmerman would be guilty of assault under Florida law. See Fla. Stat. § 784.011(1). Moreover, Zimmerman reportedly ignored the police's instructions not to pursue Trayvon. Florida law makes it a crime if someone "resists, obstructs, or opposes" a law enforcement officer. See Fla. Stat. § 843.01. If Zimmerman is guilty either of assault or resisting an officer, he was "engag[ing] in unlawful activity" and therefore would lose the protections of the statute.

Second, the statute only permits an individual to "meet force with force, including deadly force". But the implication is that the victim must have been the first aggressor (otherwise the "second" aggressor would be initiating force, not meeting it). For the defense to hold, Trayvon must have been the first aggressor.

So Zimmerman's defense may be much weaker than it initially appears. All of the "Stand Your Ground" discussion has assumed that the law gives people free reign to shoot someone whenever they feel threatened. Although that may be the practical effect in some cases, in this case (based on the facts as reported in the media), Zimmerman can only avail himself of the defense if (a) he was not guilty of assault or resisting an officer; and (b) Trayvon initiated the fight. As to the second point, it might be easy to say that we can never know what happened because all we have left is Zimmerman's word. And there is the added wrinkle, as described by Professor Mannheimer, that a claim of self defense gives the defendant immunity from arrest and prosecution. So the claim of self-defense cannot be tested through the usual mechanisms -- unless the police have "probable cause that the force that was used was unlawful." Fla. Stat. § 776.032. It's not clear whether "unlawful" as used in Section 776.032 (to modify "force") means the same as it does in Section 776.013 (when used to modify "activity"). It may not; after all all, resisting an officer, for example, could be "unlawful activity", but it is likely not, on these facts, "unlawful force". Assault, on the other hand, could be "unlawful activity" that does involve unlawful force.

A commenter raised a good point about my initial post; it suggested that the defendant has the burden of proof to show he was acting in self-defense. Here, I elided two important but distinct concepts, one at common law and one statutory. First, the general rule is that the defendant has the burden of raising the affirmative defense, and the prosecution has the burden of proving beyond a reasonable doubt that it does not exist. Second, and important here: that question would never come up at trial, because of the immunity described above. Therefore, immunity is decided during pretrial proceedings, at which a judge decides if the defendant is immune from prosecution because he was acting in self-defense. And on this question, the defendant must show, by a preponderance of the evidence, that he was acting in self-defense. See Dennis v. Florida, 51 So. 3d 456 (Fla. 2010) ("[W]e hold that a defendant may raise the question of statutory immunity pretrial and, when such a claim is raised, the trial court must determine whether the defendant has shown by a preponderance of the evidence that the immunity attaches.") (emphasis added). So, although it is true that the defendant does not bear the burden of proving self-defense at trial, he bears the burden of proving (albeit by a lesser standard) that the immunity attaches.

No matter how you look at it, the Trayvon Martin story is tragic. There's no reason this young man had to lose his life, and I'm sure even George Zimmerman wishes he hadn't acted as he did. I just wanted to write to add a bit of legal nuance, and to show that the mere fact that Florida has this law in place doesn't mean it will necessarily protect George Zimmerman here.


  1. Great post, but I don't think the defendant bears the burden of proof on an affirmative defense (at least not in Florida). Rather, the defendant gets to raise the defense and then the prosecution has the burden to prove that the defense doesn't apply.


    1. Burden of Production v. Burden Persuasion...

    2. Hey Folks ... I've watched this trial unfold from north of the border in Canada and have to admit that as a white male I'm shocked at how this trial has unfolded. Even more horrifying is the law that allows the deliberate death of another human being to occur unchecked. Based on the law, and the limited evidence presented, I concur with the decision of the jury. However, given the lies, inaccuracies and one-sided evidence presented, is there any wonder the decision could be anything other than what it was!
      Consider this; Zimmerman ran and lunged at Martin and lost his footing and hit his nose on some solid body part of Trayvon (possibly his head or knee)which led to him breaking his own nose. I've always been perplexed that there was an obvious lack of bruising on Zimmerman's face given that he was supposed to take such a beating! I've been on both sides of a fist and the picture looks very different! Banging someone's head on concrete gives very quick results ... they are knocked unconscious very quickly!
      No, the facts just don't add up in the world I live in! Zimmerman lunged at Trayvon Martin with his gun already drawn. I believe it was in fact Trayvon who feared for his life and Zimmerman killed him in cold blood as soon as he realized he was in trouble! Something interesting I heard from both a juror and a witness was that they "definitely" believed the screams for help were that of Zimmerman even though that had never heard the voice of Trayvon for comparison! This type of evidence should never have been considered and certainly should have been refuted.
      In conclusion, this trial represents a tremendous miscarriage of justice and shows the continuing inconsistencies of law across America. Although my heart goes out to both families, the jury got this decision wrong because Zimmerman lies were believed by the jury, and the white supremacist law opened all the doors for an acceptable 'not guilty' decision. God help us all should we find ourselves in a similar situation!

  2. Thanks for clarifying. I've updated the post.

  3. Its so highly informative things are posted here. These things are the fresh and having good information are posted here, and also am seeking for this kind of information thanks for updated.

  4. MY PERSONAL OUTLOOK: George Zimmermen vs Trayvon Martin
    The stand-your-ground law states that a person may use deadly force in self-defense when there is reasonable belief of a threat, without an obligation to retreat first.and it clearly states that a person has no duty or other requirement to abandon a place in which he has a right to be, or to give up ground to an assailant.
    (With that being said,it seems that Trayvon Martin was exercising the"Stand your ground" law by defending himself against the assailant Zimmermen,whom he was Killed by.did anyone ever stop to think about that?)

  5. Interesting article. I have to say that you have the most informative posts on this blog.

  6. One wrinkle in your post, the 911 call taker is not a police officer and has no authority therefore the comment of "you dont have to do that " (follow trayvon) is not a lawful order that was not obeyed or in anyway could be construed as obstructing an officer.

  7. I think you reach a certian point a bit too quick. In your examination of a possible assault was his fear "well-founded"?

    Zimmerman would have had to communicate:
    "an **intentional**, unlawful threat by word or act to do violence to [Trayvon], coupled with an apparent ability to do so, and doing some act which create[d] a well-founded fear in [Trayvon] that such violence is imminent."

    Intent matters, not just perception. So, where is the intent to communicate a threat to do him harm?

    And do you mean 843.02?
    843.01 requires him to have used violence against the officer .02 is for obstruction/resistance without violence against the Officer, such as refusing a lawful order to disperse.

    A quick hypothetical, Trayvon Martin is at a rally, while walking he sees a LEO arresting someone so he walks over to watch. Cop says "I don't need you to be here." In fact imagine they say it very sternly while they are in the act of making the arrest. Trayvon remains and watches the arrest. The officer then arrests Trayvon for a violation of 843.02.

    Would you think such a prosecution is sustainable or reasonable?
    If not then not obeying the implied message within the communication of "We don't need you to do that" is just as wrong.

    Do I think Zimmerman is some innocent person in all this. Nope. I think his action directly contributed to if not led to the events unfolding as they did. But do I think there is such an open and shut way to shoot down a claim of self-defense. Nope.

  8. "But the implication is that the victim must have been the first aggressor (otherwise the "second" aggressor would be initiating force, not meeting it). For the defense to hold, Trayvon must have been the first aggressor.

    So Zimmerman's defense may be much weaker than it initially appears."

    It's not weaker if Martin was the aggressor.

  9. Also, you might want to update your post to reflect the claim by Zimmerman and witnesses that Martin was smacking Zimmerman's head against the sidewalk.

    If true, that could not only put Zimmerman squarely within the scope of the stand-your-ground law, but might even make the SYG irrelevant, since (I believe) even under traditional self-defense, Zimmerman had no duty to retreat if he could not do so safely (and one would think you can't "safely" retreat if you're pinned to the ground having your head smacked against the sidewalk.)

    1. Trayvon had four minutes to go 100 yards home. No way fat old, slow Zimmerman could have caught hi in a chase.
      Zimmerman retreated (got knocked back on the ground).Zimmerman did not get one punch in. Martin got on top of Zimmerman and started doing a ground and pound. A ground and pound is extremely difficult to escape from.. At this point in a fight with a referee the fight would be stopped.
      One pound of a head against concrete is enough to kill. Who at this point would not be afraid for their life?
      It was only AFTER several punches, pounds that Zimmerman stopped Martin.
      Many people seem to want to give the legal ability to attack if a white person is walking behind then and they "feel something".
      If you still a Trayvon supporter I hope you have the opportunity to reconsider while having your brains pounded out.
      Martin did not get shot in the back or at a distance. He got shot on top on Zimmerman. Be careful who you give a forced lap dance to in Florida.

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