State v. Bowens

Facts

Under New Jersey law, a homicide is murder when committed purposely or knowingly, and a homicide is aggravated manslaughter when committed under circumstances manifesting an extreme indifference to human life. The statutory definition of self-defense was amended to establish an objective standard under which the use of force is justifiable if the defendant reasonably believes that such force is immediately necessary to protect against the use of unlawful force. Anthony Rivers (Defendant) argued with a man, who picked up a knife and threatened to stab Rivers. When the man moved away, Rivers reached for a knife. When the man approached again, Rivers stabbed and killed the man, fearing for his own life. At trial, the court refused to instruct the jury on imperfect self-defense and instructed the jury on reckless manslaughter instead. The jury convicted Rivers of aggravated manslaughter. In a separate case, Leon Bowens (Defendant) had been threatened with a knife by John Booker on many occasions and knew that Booker was a violent man. One day, Booker approached Bowens, causing Bowens to fear an attack. Bowens showed Booker a knife, and Booker retreated but then approached again. Believing that Booker was going to stab him, Bowens stabbed Booker. At trial, the court refused to instruct the jury on imperfect self-defense and instructed the jury on murder and complete self-defense. The jury found Bowens guilty of first-degree murder. The appellate court reversed, finding that the trial court had erred in not charging the jury on the manslaughter offenses. The prosecution appealed. Rivers’s and Bowens’s cases were consolidated on appeal.