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by Mike S
Mon Nov 29, 2021 10:36 am
Forum: The Crime Blotter
Topic: TX: Lubbock potential self defense death occurs
Replies: 64
Views: 26062

Re: TX: Lubbock potential self defense death occurs

K.Mooneyham wrote: Mon Nov 29, 2021 1:29 am
srothstein wrote: Sun Nov 28, 2021 11:05 pm
K.Mooneyham wrote: Sun Nov 28, 2021 8:26 pm In reply to "MikeS", please define the term "butt whooping". I am curious where the line is drawn and how beaten someone has to be before it's not just a "butt whooping". How injured does someone have to be before it becomes "serious bodily injury"? Why should anyone have to put up with having someone else attempt to beat them? I'm an aircraft mechanic, and not a weakling per se, but I'm also no longer a young man. Additionally, I don't have any particular hand-to-hand fighting skills, such as tae kwando, krav maga, or kung fu. How am I to know if someone assailing me does have those skills, before it might be too late? To paraphrase that famous John Wayne character, I don't put my hands on anyone else and I shouldn't have to put up with anyone else doing that to me.
If it helps, here is the definition of serious bodily injury from the Penal Code Section 1.07(a)(46):
(46) "Serious bodily injury" means bodily injury that creates a substantial risk of death or that causes death, serious permanent disfigurement, or protracted loss or impairment of the function of any bodily member or organ.
The way I was taught, permanent disfigurement means a scar or worse. Protracted loss or impairment of any bodily member or organ means a broken bone, a sprain, or similar injury. A big portion of the problem with this definition is that a lot of it depends what the DA will accept for it. In Bexar county, it was how I said above (at least while I was on the PD there). In Caldwell county, a lot more rural and conservative, the general rule was if it required medical treatment in the ER. Calling EMS was not enough but if they transported it was.

As to your question about the other person's skills, the answer is going to rely on common sense, unfortunately. There is a legal concept the courts have used called a disparity of force. For example, a 120 lb, 5'2" female can expect more injury and use more force against a 200 lb, 6'1" young male. Same for someone like me (a 65 year old in poor shape and with sever arthritis in multiple joints) against the 20 year old man who lifts weights and works out. In both cases, the opposite holds. The young fit male cannot escalate if fighting me or the small female.

I think Mr. Branca is correct when he says that the overriding legal theory is reasonableness. Is your behavior reasonable to the average person IF he was in that situation knowing what you knew then.
I do understand the information you posted, and having taken one of Mr. Cotton's seminars many years ago, I already knew some of it. It just seems that a lot of definitions of things are out-of-date, or at least not taking current conditions into account. I'm not talking about two 1970s "good ol' boys" in a classic "barrroom brawl" after a few too many at the ol' beerjoint, nor two Victorian gentlemen settling a disagreement via fisticuffs and Marquess of Queensbury Rules. I'm talking about ruthless modern bad guys, many of whom are drugged up on who knows what all substances, trying to beat someone to death for "disrespecting them", or similar. I am certain that if a person knew where to look, they could find multiple instances of people being severely injured, or killed, by a single punch or kick. Again, I will state that no one should have to put up with someone attempting to beat them, and I simply feel that it is unreasonable to expect that. On the other hand, I do everything I can to avoid situations where that sort of thing becomes more likely to occur...but no one can avoid all trouble forever.
A key point to consider is that you don't have to wait until you've sustained a serious bodily injury or near death before being justified in self defense. You may be justified in self defense before the offender even makes physical contact with you.

What is required is that you were in jeopardy of death or serious bodily injury ((You reasonably believed that 1) the other person was actually capable of inflicting that level of injury; 2). that person was about to inflict that level of injury right now; 3) and the level of force you use to stop it was immediately necessary)).

Your belief must be reasonable. In other words, "Would a reasonable person, under those same circumstances, & knowing what you knew at that point in time, have reasonably believed that they were in immediate jeopardy of death or serious bodily injury, and reasonably believed that the force used was immediately necessary to prevent that level of injury?"

Just because someone could have skills as a fighter, or could cause a serious bodily injury if they struck us, doesn't translate as a reasonable belief that we must immediately use force/deadly force to prevent it. We must reasonably believe that they actually can; that they have the opportunity/intent to do so; & that it's imminent (going to happen right now, not a threat that it may occur in the future).

TPC 9.31/9.32 also includes some situations where that belief is "presumed to be reasonable". Murder, sexual assault, robbery, & aggravated kidnapping, or unlawfully with force attempting to enter/remove you from your occupied dwelling/vehicle/place of employment. However, we can also lose the 'presumption' of reasonableness if we provoked the incident, or were committing a crime at the time. To tie this back to the topic of this thread, I'd opine that under TPC 9.41 you can use force (not deadly force) to terminate a trespass, & that the mere presence of a weapon isn't necessarily considered deadly force based on TPC 9.04 (must already be justified in using force, & your threat is limited to deterring unlawful act of another by 'causing apprehension that you'll use deadly force if necessary) . However, since deadly force isn't justified for a mere trespassing, firing the rifle into the ground at the tresspassor's feet could be viewed as not only unlawful (TPC 22.05 Deadly Conduct)(using deadly force when only force was justified), but also as provoking an escalation. I'd argue either of those actions would likely remove the 'presumption' of reasonableness.

On the other hand, the trespassor had no legal justification for resisting the owner's use of force, but may have had a self defense claim when the owner unlawfully used deadly force. I'd argue that the trespassor wouldn't qualify for the presumption of reasonableness either, though, since he was commiting the crime of trespass, and could be argued that his conduct up to that point as provoking the incident (thus removing the presumption of reasonableness once it shifted from a trespass/defense of property to a self defense encounter).
by Mike S
Sun Nov 28, 2021 7:12 pm
Forum: The Crime Blotter
Topic: TX: Lubbock potential self defense death occurs
Replies: 64
Views: 26062

Re: TX: Lubbock potential self defense death occurs

wil wrote: Sun Nov 28, 2021 6:31 pm
wil wrote: Sun Nov 28, 2021 6:16 pm
oljames3 wrote: Sun Nov 28, 2021 3:03 pmWil, these links go to Texas Government Code chapters 311 and 312.
https://statutes.capitol.texas.gov/docs ... GV.311.htm
https://statutes.capitol.texas.gov/docs ... GV.312.htm

This article, by Texas lawyers, explains that deadly force is not justified against trespassers.
Texas Penal Code Section 9.41 explains that a person is allowed to use force, but not deadly force, to terminate a mere trespass or interference with property.
https://www.uslawshield.com/defend-property-texas/
I read the article and it does not answer some questions.

1. what constitutes 'force' under 9.41? It is not defined, only stated.

2. if it's non-lethal, what is that? Physical restraint via hands-on? Physically forcing whatever party off the property via the same? 9.41 does not define what constitutes force.

3. what is the recourse under 9.41 if that is not a viable option. Such as disparity of physical strength, outnumbered, etc.

4. the article doesn't really address a situation such as Lubbock. The individual is told to leave, doesn't and advances in a hostile and threatening manner. Are we forced to go hands-on with the genuine potential risks involved with that?
Trespass means someone has been told to leave, they refuse to do so and display hostile and aggressive intent, what is the force allowed to make them leave under 9.41?

If it is physical force only, We have no way of knowing whether or not that individual has training in unarmed combat such that they are far overmatched to ourselves.
An 60 year old individual is generally not a physical match for someone 20 or more years younger in terms of strength, speed, etc.
9.41 does not address any of these questions and it's why I brought up the fallacy of "are you going to shoot a 9 year old kid for tresspassing?' No, there is no likely physical disparity where that childs physical abilities present a danger to oneself if physical force is what is covered in 9.41. A 19 year old is a different story is a different story in terms of physical ability.

9.42 addresses these questions in terms of physical risk to oneself.

these are reasons why I tend to think 9.41 works in conjunction with 9.42 and the article doesn't specify if they are non-related and if so, why.
Also 9.41 not defining what constitutes force leaves the question as to how it applies to 9.42, which specifically mentions if force is legal under 9.41, then it seems 9.42 applies. The article does not address this or 9.42.

still the same question.
Edit: here is 9.42 in it's entirety.

Sec. 9.42. DEADLY FORCE TO PROTECT PROPERTY. A person is justified in using deadly force against another to protect land or tangible, movable property:

(1) if he would be justified in using force against the other under Section 9.41; and

(2) when and to the degree he reasonably believes the deadly force is immediately necessary:

(A) to prevent the other's imminent commission of or

(B) to prevent the other who is fleeing immediately after committing burglary, robbery, aggravated robbery, or theft during the nighttime from escaping with the property; and

(3) he reasonably believes that:

(A) the land or property cannot be protected or recovered by any other means; or

(B) the use of force other than deadly force to protect or recover the land or property would expose the actor or another to a substantial risk of death or serious bodily injury.

the things that stand out in this:

part 1. if force is justified under 9.41. Tresspass and they refuse to leave.

item B under part three, to protect land and if doing so would expose the actor to a substantial risk of death or serious bodily injury.

Perhaps it does beg the question, do we have to have every single element of that entire section of the code in place to use lethal force under 9.41? or are those sections attempting to address individual situations?

9.41 allows for force, depending on what that actually is, if it's non-lethal, then what happens if that's not a viable option for the individual? Such as the examples I gave? And it exposes someone to grave risk of injury or death?

Then my thinking is 9.42 covers that in part (A) cant be done by any other means, or part (B) places oneself in grave physical risk.

I could be wrong however that seems to be a reasonable line of thinking.
You are correct in that the TPC doesn't define "force". Here's what I posted earlier in this thread that you may have not seen. https://texaschlforum.com/viewtopic.php ... 4#p1316164

Bottom line up front, "Force" is non-lethal force. "Deadly Force" is defined in the Texas Penal Code (TPC)., & means force that can cause 'death', OR 'serious bodily injury'. "Serious Bodily Injury" is also defined by the TPC, & means an injury that will put you out of commission for a bit, not just a butt whooping. I'll edit later & put the actual definition here so it's not just me pulling it out of my hip pocket. ETA: Here's the TPC definition of Serious Bodily Injury:
"Serious bodily injury" means bodily injury that creates a substantial risk of death or that causes death, serious permanent disfigurement, or protracted loss or impairment of the function of any bodily member or organ.
For clarification, to be justified under 9.42 you'd need:
(1) to already be justified in using "force' under 9.41 (the TPC lists things when 'force' is never justified, such as for verbal provocative alone; when you provoked the incident; when you're committing a crime);

--AND--

(2) you must reasonably believe that deadly force is immediately necessary to prevent or stop one of these things:
arson, burglary, robbery, aggravated robbery, theft during the nighttime, or criminal mischief during the nighttime;
--OR--
to prevent the other who is fleeing immediately after committing burglary, robbery, aggravated robbery, or theft during the nighttime from escaping with the property;

--BUT ONLY IF you reasonably believe that--

(3) the land or property cannot be protected or recovered by any other means (protected from one of the acts listed above);
--OR--
the use of force other than deadly force to protect or recover the land or property would expose the actor or another to a substantial risk of death or serious bodily injury (protect the property from one of the acts listed above)

I'm hoping that makes a little more sense out of 9.41 & 9.42. I'll attempt to address the other part of your post in a bit.
by Mike S
Fri Nov 26, 2021 10:19 pm
Forum: The Crime Blotter
Topic: TX: Lubbock potential self defense death occurs
Replies: 64
Views: 26062

Re: TX: Lubbock potential self defense death occurs

Oljames' interpretation is correct. Deadly force is absolutely NOT justified for mere trespassing.

When reading the penal code, AND's & OR's are important clauses. "And" requires both elements be present (if multiple elements are listed with "and" between them, then all the listed elements must be satisfied).

"Or" means one of the listed elements must be satisfied.

Under Texas law (TPC 9.41 / 9.42) deadly force is NOT justified for trespass. Force IS justified to prevent or stop a trespass (9.41), but only reasonable 'force' that is immediately necessary.

Unfortunately, the TPC doesn't define "Force". Therefore, the commonly understood meaning of 'force' is used.

These definitions of force are from Black's Law Dictionary:
force,n. Power, violence, or pressure directed against a person or thing.

force,vb. To compel by physical means or by legal requirement

reasonable force. Force that is not excessive and that is appropriate for protecting oneself or one's property.

unreasonable force Unreasonable or unnecessary force under the circumstances.
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And, it's the jury selected for your trial that will be the arbiters of whether it was reasonable under the circumstances.

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