Brown v. United States case brief

Brown v. United States case brief summary
256 U.S. 335 (1921)

CASE SYNOPSIS

Defendant sought review of a judgment of the Circuit Court of Appeals for the Fifth Circuit judgment, which affirmed defendant's conviction of murder in the second degree.

CASE FACTS
Defendant was convicted of second degree murder. He contended on appeal that the trial court gave erroneous jury instructions regarding his duty to retreat. The appellate court affirmed his conviction.

DISCUSSION

• On certiorari, the Court held that because defendant and the victim had a long history of conflict and because there was evidence that the victim had initiated the fatal attack, the trial court erred by instructing the jury that defendant was required to attempt retreat before claiming self-defense. 
• In reversing, the Court held that the jury could have reasonably concluded that defendant feared for his life and that there was substantial evidence that the shooting was in self-defense. 
• It was not necessary for defendant to engage in detached reflection before firing the fatal gunshot.

CONCLUSION
The Court reversed the judgment of the appellate court, which had affirmed the trial court's judgment convicting defendant.

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