People v. Hecker
Supreme Court of California
42 P. 307 (1895)
After finding Riley's strayed horses for a promised reward, Hecker (defendant) returned them to a neighboring barn and claimed a lien against the reward, but Riley grew suspicious, accused Hecker of having stolen the horses, and refused payment; Hecker later armed himself, retrieved one horse while warning Riley he was armed, and subsequently pursued the second horse to the barn, where he grappled with Riley, struck him with a pistol, and the two men exchanged repeated gunfire — during which Hecker allegedly moved around trying to escape and Riley called for more ammunition — before Hecker fatally shot Riley. Hecker was convicted of second-degree murder and appealed, claiming self-defense.
Whether a defendant may successfully claim self-defense for a killing that arose from an escalating mutual physical conflict over disputed property, when both parties exchanged repeated gunfire.