Jahnke v. State

Richard Jahnke (plaintiff), a 16-year-old, was convicted of manslaughter after he killed his father, who he alleged severely mentally and physically abused him, his mother, and his sister daily for most of Jahnke’s life. Jahnke’s father was a brutal, gun-toting man who the day of the murder had severely beaten Jahnke, vowed to “get rid” of Jahnke, and told Jahnke to be gone from the family’s home upon his return. Just weeks before the murder, Jahnke had reported the abuse to the local sheriff at the encouragement of his Reserve Officers’ Training Corps (ROTC) instructor, whose home Jahnke fled to following one of his father’s brutal attacks. However, the night of the murder, after his father’s earlier beating and threats, Jahnke laid in wait in the family’s garage with his sister, armed in his defense and with weapons scattered throughout the house for backup, and shot and killed his father when he returned to the family home. At trial, Jahnke claimed that he killed his father in self-defense and sought to present evidence from a psychiatric expert regarding battered-person syndrome. The trial court excluded the expert testimony as irrelevant to Jahnke’s self-defense plea because self-defense is based on a reasonableness standard. Jahnke appealed his conviction, alleging that the trial court erred in excluding the psychiatric testimony in support of his self-defense claim.