State v. Bowens

New Jersey law makes homicide murder when committed purposely or knowingly, and defines self-defense objectively: force is justified only if the defendant reasonably believed it was immediately necessary to protect against unlawful force. In a companion case, Anthony Rivers stabbed a man to death after the man had threatened him with a knife, retreated, then approached again; the trial court refused an imperfect-self-defense instruction but instructed on reckless and aggravated manslaughter, and the jury convicted Rivers of aggravated manslaughter. In this case, Leon Bowens (defendant), who had been repeatedly threatened with a knife by a violent man named John Booker, stabbed Booker to death after Booker approached him a second time following a retreat; the trial court refused an imperfect-self-defense instruction and instructed only on murder and complete self-defense, and the jury convicted Bowens of first-degree murder. The appellate court reversed Bowens's conviction, holding the trial court should have instructed on manslaughter offenses, and the prosecution appealed; the two cases were heard together.