United States v. Garcia (1980)

Prison inmates Eugene Pete Garcia, Joe Anthony Contreras, and David Lucero (defendants) were prosecuted for the murder of fellow inmate Michael Martinez, who had previously threatened Garcia's life. Garcia armed himself with a knife in anticipation of a confrontation and approached Martinez; witnesses said Martinez then pulled his own knife and attacked, and the fight spread into a corridor where guards ordered the men to stop, which they ignored. Guards saw Garcia, Contreras, and Lucero chase down and catch Martinez, with Contreras and Lucero holding him down while Garcia fatally stabbed him. Garcia claimed self-defense, and the judge instructed the jury that if Garcia provoked the attack, self-defense would only excuse the killing if Garcia reasonably believed he was in mortal danger and had first exhausted every reasonable defensive measure short of deadly force. The jury convicted all three, and Garcia appealed, arguing there was no evidence he provoked Martinez.