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United States v. Biggs

United States Court of Appeals for the Ninth Circuit
441 F.3d 1069 (2006)

Written by Jamie Milne, JD

Facts

Donzell Biggs (defendant) was in prison serving a life sentence for murder. Biggs was in the administrative-segregation unit, where inmates were confined to two-person cells for 23 hours of the day. For one hour per day, the inmates were in a recreation cell with three other inmates. During this recreation hour, Biggs attacked fellow inmate Michael Smith with a homemade knife. Biggs claimed that Smith threatened Biggs on the way to the recreation cell and that Biggs knew Smith had been trying to acquire a knife from other inmates. Based on these facts, Biggs alleged that his use of force against Smith was self-defense. Biggs pled guilty to assault with a dangerous weapon and possession of contraband in prison. However, Biggs reserved the right to appeal on the ground that the district court erred in finding that Biggs had not made a prima facie case for self-defense. The district court determined that Biggs had failed to demonstrate a lack of reasonable alternatives to the use of force against Smith and rejected Biggs’s claim of self-defense. Biggs appealed the decision.

Rule of Law

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Issue

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Holding and Reasoning (Beezer, J.)

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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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