Perrin v. Anderson
United States Court of Appeals for the Tenth Circuit
784 F.2d 1040 (1986)
Terry Kim Perrin behaved erratically and then attacked two police officers (defendants) who came to question him about a car accident, repeatedly kicking and punching one officer before that officer shot and killed him; Perrin's estate (plaintiff) sued the officers for civil-rights violations, and the officers claimed self-defense. At trial, four of eight offered police witnesses testified to five separate specific incidents in which Perrin had reacted violently toward police, describing him as someone who hated and always reacted violently to police contact, with no evidence offered of any peaceful police encounters; the trial court admitted this testimony as both character evidence under Rule 404 and habit evidence under Rule 406, and the jury found for the officers, prompting the estate's appeal.
Whether evidence of a victim's consistently violent history in encounters specifically with police officers is admissible to support a claim that officers acted in self-defense when they shot and killed him.