Montana Supreme Court
State v. E. Holcomb
August 26, 20252025 MT 190
Summary
The Montana Supreme Court affirmed Holcomb's deliberate-homicide conviction, holding that the trial court did not abuse its discretion by refusing to instruct the jury on justifiable use of force. The evidence did not support a reasonable belief that Holcomb faced imminent death or serious bodily harm when he shot Trysten. The court found no evidence that Trysten physically attacked Holcomb, drove threateningly toward him, fired at him, or otherwise created an imminent threat before the shooting.