State v. Studd

Summary

The court held that self-defense instructions based on WPIC 16.02 misstated the law by failing to make clear that a defendant may act on a subjectively reasonable belief of imminent harm even when actual danger is absent. Under the invited-error doctrine, defendants who requested the erroneous instruction could not obtain new trials, although a defendant who requested an omitted curative instruction could challenge the resulting error. The court affirmed the convictions in Studd, Cook, Bennett, and McLoyd, while affirming reversals and new trials in Ameline and Fields.