State v. Leidholm
Supreme Court of North Dakota
334 N.W.2d 811 (1983)
Leidholm (defendant) was in an abusive marriage in which both spouses drank heavily and were sometimes violent. Coming home from a party where both had been drinking, she and her husband Chester began arguing, which escalated into a physical fight; Chester stopped her from calling for help and repeatedly pushed her to the ground. After the fight ended and they went to bed, Leidholm got up, took a butcher knife from the kitchen, and stabbed Chester to death. She was tried for murder, claimed self-defense, and introduced expert testimony on battered woman syndrome; the trial court refused her requested instruction that the syndrome could be relevant to self-defense and instead instructed the jury using an objective "reasonably prudent person" standard. Leidholm was convicted of manslaughter and appealed.
Whether, if the court correctly instructs the jury that a subjective standard of reasonableness applies in self-defense cases, it must also give an additional instruction on the relevance of battered woman syndrome.