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State v. Leidholm

Supreme Court of North Dakota
334 N.W.2d 811 (1983)


Facts

Leidholm (defendant) was in an unhappy marriage with Chester, her husband, in which both parties abused alcohol and engaged in violent behavior. On returning home from a party at which both of them had been drinking heavily, the two started an argument which turned into a fight. Chester prevented Leidholm from calling a deputy sheriff and repeatedly pushed her to the ground. After the fight stopped and they had gone to bed, Leidholm got up, went to the kitchen, took a butcher knife, and stabbed Chester to death. Leidholm was charged with murder and tried in the McLean County Court. At her trial, Leidholm claimed that she had acted in self-defense and introduced expert testimony that she suffered from battered woman syndrome. The court refused Leidholm’s request for an instruction that this syndrome could be relevant to the issue of self-defense. The court instead instructed the jury that self-defense under North Dakota law applied only if a reasonably prudent person in similar circumstances would have reasonably believed that Chester was about to kill her or inflict serious bodily harm. Leidholm was convicted of manslaughter and appealed to the Supreme Court of North Dakota.

Rule of Law

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Issue

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Holding and Reasoning (Vande Walle, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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