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Watson v. United States

District of Columbia Court of Appeals
501 A.2d 791 (1985)


Two police officers saw Watson (defendant) driving a stolen car and ordered him to stop. Watson jumped out of the car and, with Officer Lunning in pursuit with his gun drawn, ran into an apartment where three girls were doing their homework. Watson asked to use the phone, dialed a number, and asked the other party “[Are] they still out there?” Lunning entered the apartment with gun drawn, placed Watson under arrest, and threatened to kill Watson when Watson objected to being put in handcuffs. Watson then initiated a struggle with Lunning, during which Lunning’s gun fell to the floor. When Watson eventually succeeded in holding Lunning down, Lunning said “[i]t wasn’t worth it.” After Watson took the gun and held it against Lunning’s chest, the officer repeated the same words. Two of the girls who had fled heard a shot shortly thereafter, and one of them saw Watson leaving the apartment with the officer’s gun in his hand, followed by Lunning, who collapsed and subsequently died. Watson was arrested at the scene and charged with first degree murder. Watson was convicted, and the trial court denied his motion for acquittal notwithstanding the verdict. Watson appealed the denial of the motion to the District of Columbia Court of Appeals.

Rule of Law


Holding and Reasoning (Rogers, J.)

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