State v. Crawford
Supreme Court of Kansas
253 Kan. 629 (1993)
Crawford (defendant), a drug addict indebted to his dealer Bateman, was pressured by Bateman into committing a string of armed robberies and a kidnapping to pay off the debt, ultimately holding a victim, Monhollon, at gunpoint for an extended crime spree before Monhollon escaped and called police. At trial, Crawford argued Bateman had threatened to kill him and his son and introduced expert testimony about his drug dependency and psychological vulnerability to Bateman; the trial court instructed the jury that only an immediate, continuing threat -- not a threat of future harm -- could support a compulsion defense. Crawford was convicted on all counts and appealed.
Whether the defense of compulsion applies only when the defendant faces an immediate and continuous danger, has no opportunity to escape, and did not place himself in peril through his own intentional or reckless conduct.