United States v. Biggs
United States Court of Appeals for the Ninth Circuit
441 F.3d 1069 (2006)
Relevant factsFree
Prison inmate Biggs (defendant), serving a life sentence, attacked fellow inmate Smith with a homemade knife during a shared recreation hour after Smith allegedly threatened him and was known to be seeking a weapon; Biggs pleaded guilty to assault while reserving his right to appeal the district court's rejection of his self-defense claim, which the district court found deficient because Biggs failed to show he lacked reasonable alternatives to using force.
IssueFree
Whether a defendant needs to show a lack of reasonable alternatives to the use of force in order to establish a prima facie case for self-defense.