Jarvis v. State

CourtCourt of Appeals of Maryland
DecidedAugust 12, 2024
Docket22/23
StatusPublished

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Bluebook
Jarvis v. State, (Md. 2024).

Opinion

Circuit Court for Cecil County Case No. C-07-CR-19-000806

Argued: April 5, 2024 IN THE SUPREME COURT

OF MARYLAND

No. 22

September Term, 2023 ______________________________________

AARON JARVIS

v.

STATE OF MARYLAND ______________________________________

Fader, C.J. Watts *Hotten Booth Biran Gould Eaves,

JJ. ______________________________________

Dissenting Opinion by Watts, J., which Gould, J., joins. ______________________________________

Filed: August 12, 2024

*Hotten, J., now a Senior Justice, participated in the hearing and conference of this case while an active member of this Court. After being Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State recalled pursuant to the Maryland Constitution, Government Article) this document is authentic. Article IV, § 3A, she also participated in the 2024.08.12 decision and adoption of this opinion. 11:51:00 -04'00'

Gregory Hilton, Clerk Respectfully, I dissent. I would hold that the Circuit Court for Cecil County abused

its discretion in refusing to instruct the jury on imperfect self-defense and that its abuse of

discretion was not harmless. The majority opinion holds that “the record shows that there

was no evidence that Petitioner subjectively believed his use of deadly force was necessary

for his safety[,]” and therefore “the trial judge did not err in declining to instruct the jury

on imperfect self-defense.” Maj. Slip Op. 31. The Majority opinion perceives this as the

correct result because, according to it, there were “two accounts of the events leading up

to Petitioner stabbing Mr. Durrett”— “Under one, the stabbing was accidental. Under the

other, the stabbing was intentional and unprovoked.” Maj. Slip Op. at 17.

There are at least two important aspects of the majority opinion with which I

disagree. First, the Majority does not consider the evidence admitted at trial in its entirety

and, in not doing so, fails to recognize that there was sufficient circumstantial evidence

from which it could be inferred that Aaron Jarvis, Petitioner, feared serious bodily injury

and stabbed Ethan Durrett because he believed it necessary to protect himself.

Second, the Majority takes an idiosyncratic approach to case law that largely ignores

that the question before this Court is whether Mr. Jarvis generated “some evidence” to

support giving the instruction and that it is acceptable for a defendant to pursue inconsistent

defenses. The Majority focuses on the circumstance that, according to it, the stabbing was

either accidental or intentional and unprovoked and therefore concludes that the imperfect

self-defense instruction should not have been given. Under our case law, however, the

question is not whether the stabbing was accidental, intentional, or unprovoked. The

question is whether Mr. Jarvis believed that he was in danger of harm and believed that the force he used was necessary to prevent the harm. Relying on a 1967 civil case that

addresses the standard of proof required for a plaintiff to establish a prima facie case of

negligence, the Majority concludes that the same standard should apply in this case. With

respect to jury instructions in criminal cases, however, case law makes clear that a

defendant need generate only “some evidence” in support of a requested instruction for it

to be given and that the “some evidence” standard may be satisfied by both circumstantial

and direct evidence, and that a defendant may pursue inconsistent defenses. See, e.g.,

Bazzle v. State, 426 Md. 541, 551, 45 A.3d 166, 171-72 (2012).

Although things such as provocation and intent may be factors in assessing a

defendant’s subjective belief, they are not dispositive. The existence or nonexistence of

provocation is not what the giving of a self-defense instruction is based on. Rather, there

must be some evidence that the defendant feared imminent harm and that the defendant

believed the use of force at issue was necessary to prevent it. In this case, taking the

evidence in the light most favorable to Mr. Jarvis, under a correct application of case law,

there was sufficient evidence to generate an imperfect self-defense instruction. The record

demonstrates that while pursing inconsistent defenses of accident and self-defense, Mr.

Jarvis generated sufficient evidence, both direct and circumstantial, to warrant the giving

of an imperfect self-defense instruction. A rational juror could easily have determined that

Mr. Jarvis feared serious bodily harm and stabbed Mr. Durrett because he believed it was

necessary to protect himself.

-2- I. The Imperfect Self-Defense Jury Instruction

In this case, Mr. Jarvis pursued two theories of defense: self-defense and accident.

Based on the evidence, all of the requirements for a jury instruction on imperfect self-

defense were met, including that there was “some evidence” that Mr. Jarvis believed he

was in “apparent imminent or immediate danger of death or serious bodily harm from” Mr.

Durrett, the victim (regardless of whether that belief was reasonable), and that there was

“some evidence” that he believed that “the amount of force used was necessary” (regardless

of whether that belief was reasonable). Porter v. State, 455 Md. 220, 234-35, 240, 166

A.3d 1044, 1053, 1056 (2017) (cleaned up).1 There was ample evidence that Mr. Jarvis

feared serious bodily harm by Mr. Durrett, i.e., believed that he was in danger, and that,

while the two men were in a physical altercation, Mr. Jarvis believed that using a

pocketknife was necessary for his own safety, i.e., believed that the amount of force he

used was necessary.

To generate a jury instruction on self-defense, a defendant need only meet the

“minimal” burden of pointing to “some evidence”—i.e., “any evidence”—that, “if

believed, would support his claim that he acted in self-defense[.]” Porter, 455 Md. at 240,

1 It is undisputed that the other requirements for the jury instruction on imperfect self-defense were met. In its brief in the Appellate Court, the State acknowledged that the jury instruction on imperfect self-defense was a correct statement of the law and not fairly covered by the jury instructions given, which are two requirements for jury instructions. See Rainey v. State, 480 Md. 230, 255, 280 A.3d 697, 711 (2022) (cleaned up). Additionally, the State does not contest that there was “some evidence” that Mr. Jarvis was not the “aggressor or” the one who “provoked the conflict[,]” or that there was “some evidence” that he “believed that retreat was not safe[.]” Porter, 455 Md. at 235, 240, 166 A.3d at 1053, 1056 (cleaned up).

-3- 166 A.3d at 1056 (cleaned up). “[I]n evaluating whether competent evidence exists to

generate the requested instruction, we view the evidence in the light most favorable to the

accused.” Bazzle, 426 Md. at 551, 45 A.3d at 172 (cleaned up). These principles apply

regardless of whether the requested instruction concerns perfect or imperfect self-defense.

Our case law indicates that, where an instruction on perfect self-defense is

generated, almost always, an instruction on imperfect self-defense is also generated. See

Roach v. State, 358 Md. 418, 434, 749 A.2d 787, 795 (2000). Perfect self-defense requires

that a person believe themself to be in apparent imminent or immediate danger of death or

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