State of Arizona v. John Logan Brown

Summary

The Arizona Supreme Court held that a separately lockable bedroom within a condominium can constitute a residential structure and premises under Arizona's justification statutes. Because the evidence provided at least slight support for Brown's claims that the victim forcefully entered the bedroom and posed a threat, the trial court erred by refusing requested instructions on the residential-structure presumption, defense of a residential structure, and defense of premises. The instructional errors were not harmless because they removed the State's burden to disprove justification beyond a reasonable doubt, so the court vacated Brown's conviction and sentence and remanded for a new trial. The Chief Justice dissented, concluding that the entire condominium, rather than the bedroom, was the residential structure.