Watkins v. State

555 A.2d 1087 (1989)

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Watkins v. State

Maryland Court of Special Appeals
555 A.2d 1087 (1989)

Facts

Bruce Dwight Watkins (defendant) stabbed a person to death during a fight (the victim). Most of the witnesses at Watkins’s trial testified that Watkins initiated the fight at a nondeadly level but that during the fight, Watkins picked up a knife and stabbed the victim. However, Watkins testified that he was not the initial aggressor. According to Watkins, the victim attempted to stab him and, while the two wrestled over the knife, Watkins stabbed the victim. Watkins requested that the trial court instruct the jury that a person who initiates a fight at a nondeadly level may claim self-defense if the other party escalates the fight to the deadly level. The trial court denied Watkins’s request and instead instructed the jury that if the victim was the aggressor, then Watkins was entitled to defend himself with appropriate force, but that if Watkins were the aggressor, then he was not entitled to claim self-defense. The jury found Watkins guilty of second-degree murder. Watkins appealed, arguing that the trial court had erred by failing to give the jury his requested instruction.

Rule of Law

Issue

Holding and Reasoning (Moylan, J.)

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