justification defense (Michigan) · Go Syfert
← Michigan issues

justification defense in Michigan

15 Michigan opinions name it 2 courts 1974–2026 4 in the last five years

The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (22)

CaseFollowedCited
People v. . Tomlinsgreen
ny · 1914 · cited in 3 Michigan opinions naming this issue, 1974–1988
2 sentences

1988Justice Cardozo, in People v Tomlins, 213 NY 240, 243 ; 107 NE 496, 497 (1914), observed: "It is not now, and never has been the law that a man assailed in his own dwelling, is bound to retreat.

1988Justice Cardozo, in People v Tomlins, 213 NY 240, 243 ; 107 NE 496, 497 (1914), observed: "It is not now, and never has been the law that a man assailed in his own dwelling, is bound to retreat.

23
United States v. Deleveauxgreen
ca11 · 2000 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009The justification defense recognized by many state and federal courts is "`very narrow[ ]'" and is to be used only in "`extraordinary circumstances'" where there is "`imminent danger.'" United States v. White, 552 F.3d 240, 247 (C.A.2, 2009), quoting in part United States v. Deleveaux, 205 F.3d 1292, 1297 (C.A.11, 2000) and United States v. Perrin, 45 F.3d 869, 874-875 (C.A.4, 1995).

2009The justification defense recognized by many state and federal courts is “ ‘very narrowO’ ” and is to be used only in “ ‘extraordinary circumstances’ ” where there is “ ‘imminent danger.’ ” United States v White, 552 F3d 240, 247 (CA 2, 2009), quoting in part United States v Deleveaux, 205 F3d 1292, 1297 (CA 11, 2000), and United States v Perrin, 45 F3d 869, 874-875 (CA 4, 1995).

22
United States v. Charles Odell Perringreen
ca4 · 1995 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009The justification defense recognized by many state and federal courts is “ ‘very narrowO’ ” and is to be used only in “ ‘extraordinary circumstances’ ” where there is “ ‘imminent danger.’ ” United States v White, 552 F3d 240, 247 (CA 2, 2009), quoting in part United States v Deleveaux, 205 F3d 1292, 1297 (CA 11, 2000), and United States v Perrin, 45 F3d 869, 874-875 (CA 4, 1995).

2009Indeed, “[i]t has been only on the rarest of occasions that our sister circuits have found defendants to be in the type of imminent danger that would warrant the application of a justification defense.” Perrin, supra at 874 .

22
United States v. Marcos Perezgreen
ca7 · 1996 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009See Butler, 485 F.3d at 575 , quoting United States v. Perez, 86 F.3d 735, 737 (C.A.7, 1996) ("We must take care not to transform the narrow, non-statutory justification exception ... into something permitting a felon to possess a weapon for extended periods of time in reliance on some vague `fear' of street violence.

2009See Butler, 485 F3d at 575 , quoting United States v Perez, 86 F3d 735, 737 (CA 7, 1996) (“We must take care not to transform the narrow, non-statutory justification exception . . . into something permitting a felon to possess a weapon for extended periods of time in reliance on some vague ‘fear’ of street violence.

22
United States v. Whitegreen
ca2 · 2009 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009The justification defense recognized by many state and federal courts is "`very narrow[ ]'" and is to be used only in "`extraordinary circumstances'" where there is "`imminent danger.'" United States v. White, 552 F.3d 240, 247 (C.A.2, 2009), quoting in part United States v. Deleveaux, 205 F.3d 1292, 1297 (C.A.11, 2000) and United States v. Perrin, 45 F.3d 869, 874-875 (C.A.4, 1995).

2009The justification defense recognized by many state and federal courts is “ ‘very narrowO’ ” and is to be used only in “ ‘extraordinary circumstances’ ” where there is “ ‘imminent danger.’ ” United States v White, 552 F3d 240, 247 (CA 2, 2009), quoting in part United States v Deleveaux, 205 F3d 1292, 1297 (CA 11, 2000), and United States v Perrin, 45 F3d 869, 874-875 (CA 4, 1995).

22
United States v. Richard Williamsgreen
ca2 · 2004 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009Instructive is United States v. Williams, 389 F.3d 402, 404 (C.A.2, 2004), in which the defendant admitted that he took a firearm from a 15 year old to "`get the gun off the street,'" and while he was headed for an incinerator to dispose of the gun, he dropped it when confronted by the police.

2009Instructive is United States v Williams, 389 F3d 402, 404 (CA 2, 2004), in which the defendant admitted that he took a firearm from a 15 year old to “ ‘get the gun off the street,’ ” and while he was headed for an incinerator to dispose of the gun, he dropped it when confronted by the police.

22
United States v. Juan Deshannon Butlergreen
ca10 · 2007 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009See Butler, 485 F.3d at 575 , quoting United States v. Perez, 86 F.3d 735, 737 (C.A.7, 1996) ("We must take care not to transform the narrow, non-statutory justification exception ... into something permitting a felon to possess a weapon for extended periods of time in reliance on some vague `fear' of street violence.

2009See Butler, 485 F3d at 575 , quoting United States v Perez, 86 F3d 735, 737 (CA 7, 1996) (“We must take care not to transform the narrow, non-statutory justification exception . . . into something permitting a felon to possess a weapon for extended periods of time in reliance on some vague ‘fear’ of street violence.

22
People v. Hernandez-Garciagreen
mich · 2007 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009Dupree's trial counsel was correct; although the jury might have been instructed under the now-defunct momentary innocent possession theory as an alternative basis for excusing Dupree's continued possession after the fight ended, see People v. Hernandez-Garcia, 477 Mich. 1039, 1040 , 728 N.W.2d 406 (2007), *484 overruling People v. Coffey, 153 Mich.App. 311 , 395 N.W.2d 250 (1986), this defense was distinct from the justification defense presented by Dupree's trial counsel.

2009Dupree’s trial counsel was correct; although the jury might have been instructed under the now-defunct momentary innocent possession theory as an alternative basis for excusing Dupree’s continued possession after the fight ended, see People v Hernandez-Garcia, 477 Mich 1039, 1040 (2007), overruling People v Coffey, 153 Mich App 311 ; 395 NW2d 250 (1986), this defense was distinct from the justification defense presented by Dupree’s trial counsel.

22
State v. Padillagreen
hawapp · 2007 · cited in 2 Michigan opinions naming this issue, 2009–2009
2 sentences

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

12
Hoffman v. United Statesgreen
scotus · 1951 · cited in 1 Michigan opinions naming this issue, 2026–2026
1 sentence

2026To that end, in order to compel the answer it must be “perfectly clear to the court ‘from a careful consideration of all of the circumstances in the case, that a witness is mistaken, and that the answer[s] cannot possibly have such a tendency to incriminate.’ ” Id. at 169, quoting Hoffman, 341 US at 488 (alteration in original).

11
PCS4LESS, LLC v. Stocktongreen
michctapp · 2011 · cited in 1 Michigan opinions naming this issue, 2026–2026
1 sentence

2026Accord PCS4LESS, 291 Mich App at 678 , and In re Morganroth, 718 F2d 161, 167 (CA 6, 1983) (the privilege should be applied liberally but cannot be applied “if it clearly appears that [the witness] is mistaken as to the justification for the privilege in advancing his claim as a subterfuge”).

11
Virginia v. Blackgreen
scotus · 2003 · cited in 1 Michigan opinions naming this issue, 2024–2024
2 sentences

2024See Black, 538 US at 359 (noting that true threats include “statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals”) (emphasis added); id. at 360 (“Intimidation in the constitutionally proscribable sense of the word is a type of true threat, where a speaker directs a threat to a person or group of persons with the intent of placing the victims in fear of bodily harm or death.”) (emphasis added); id. (referring to the “fear of violence”) (emphasis added; 15 The prosecutor argues

2024See Black, 538 US at 359 (noting that true threats include “statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals”) (emphasis added); id. at 360 (“Intimidation in the constitutionally proscribable sense of the word is a type of true threat, where a speaker directs a threat to a person or group of persons with the intent of placing the victims in fear of bodily harm or death.”) (emphasis added); id. (referring to the “fear of violence”) (emphasis added; 15 The prosecutor argues

11
United States v. James Thomas Nolangreen
ca9 · 1983 · cited in 1 Michigan opinions naming this issue, 2009–2009
1 sentence

2009See, e.g., United States v. Lemon, 824 F.2d 763, 765 (C.A.9, 1987) (finding that no imminent danger existed when the defendant's attacker had left the scene); see, also, United States v. Nolan, 700 F.2d 479, 484 (C.A.9, 1983) (holding that the justification defense was inapplicable when the defendant pursued the alleged assailant after the assailant left the bar).

11
United States v. Oliver F. Lemongreen
ca9 · 1987 · cited in 1 Michigan opinions naming this issue, 2009–2009
1 sentence

2009See, e.g., United States v. Lemon, 824 F.2d 763, 765 (C.A.9, 1987) (finding that no imminent danger existed when the defendant's attacker had left the scene); see, also, United States v. Nolan, 700 F.2d 479, 484 (C.A.9, 1983) (holding that the justification defense was inapplicable when the defendant pursued the alleged assailant after the assailant left the bar).

11
Ex Parte Taylorgreen
ala · 1993 · cited in 1 Michigan opinions naming this issue, 2009–2009
11
United States v. Alphonso Buster Gilbert, Sr.green
ca4 · 2005 · cited in 1 Michigan opinions naming this issue, 2009–2009
1 sentence

2009See, e.g., United States v. Baker, 508 F.3d 1321, 1325-1327 (C.A.10, 2007); United States v. Johnson, 459 F.3d 990, 996-997 (C.A.9, 2006), and United States v. Gilbert, 430 F.3d 215, 218-220 (C.A.4, 2005), and the cases they cite. [6] Both the lead opinion and the concurrence seem to overlook that fact, but the whole premise of their conclusion is based on transforming a duress defense (that was never requested) into a justification defense (that was never requested). [7] Or it could also be safely concluded that defendant has waived the issue by failing to raise the issue before the trial cou

11
United States v. William Johnsongreen
ca9 · 2006 · cited in 1 Michigan opinions naming this issue, 2009–2009
11
Marrero v. Stategreen
fladistctapp · 1987 · cited in 1 Michigan opinions naming this issue, 2009–2009
1 sentence

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

11
United States v. Bakergreen
ca10 · 2007 · cited in 1 Michigan opinions naming this issue, 2009–2009
11
People v. Wadkinsgreen
michctapp · 1980 · cited in 1 Michigan opinions naming this issue, 1986–1986
11
Commonwealth v. Golstongreen
mass · 1977 · cited in 1 Michigan opinions naming this issue, 1980–1980
11
Kaptur v. Kapturgreen
ohioctapp · 1934 · cited in 1 Michigan opinions naming this issue, 1980–1980
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (22)

CaseCitedYears
Commonwealth v. Vasquez green
mass · 2012
2 sentences

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

22022–2022
People v. Powell green
cal · 2018
2 sentences

2022However, Anderson, id. at 784, acknowledged, and the court reaffirmed in People v Powell, 6 Cal 5th 136, 164; 425 P3d 1006 (2018), that duress may be raised as a defense to felony murder if it is a defense to the underlying felony.

2022However, Anderson, id. at 784, acknowledged, and the court reaffirmed in People v Powell, 6 Cal 5th 136, 164; 425 P3d 1006 (2018), that duress may be raised as a defense to felony murder if it is a defense to the underlying felony.

22022–2022
People v. Anderson green
cal · 2002
2 sentences

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

22022–2022
People v. Serrano green
illappct · 1997
2 sentences

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

2022With respect to the courts that have addressed duress in the context of homicide accusations, nearly every case involved an intentional killing, and to the extent that unintentional killings have been discussed, it has generally been in dicta. 8 For example, in for all crimes except “an act by which one intentionally or recklessly causes physical injury to another”); Kan Stat Ann 21-5206 (allowing a duress defense for all crimes except murder or voluntary manslaughter); La Stat Ann 14:18 (defining duress as a justification defense but excluding “murder”); Mo Rev Stat 562.071 (making duress ava

22022–2022
Humphrey v. Commonwealth green
vactapp · 2001
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
State v. Parker neutral
washctapp · 2005
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
Commonwealth v. McCambridge green
massappct · 1998
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
People v. Jones neutral
nysupct · 2004
2 sentences

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
State v. Crawford green
md · 1987
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
People v. Coffey green
michctapp · 1986
2 sentences

2009Dupree’s trial counsel was correct; although the jury might have been instructed under the now-defunct momentary innocent possession theory as an alternative basis for excusing Dupree’s continued possession after the fight ended, see People v Hernandez-Garcia, 477 Mich 1039, 1040 (2007), overruling People v Coffey, 153 Mich App 311 ; 395 NW2d 250 (1986), this defense was distinct from the justification defense presented by Dupree’s trial counsel.

2009Dupree’s trial counsel was correct; although the jury might have been instructed under the now-defunct momentary innocent possession theory as an alternative basis for excusing Dupree’s continued possession after the fight ended, see People v Hernandez-Garcia, 477 Mich 1039, 1040 (2007), overruling People v Coffey, 153 Mich App 311 ; 395 NW2d 250 (1986), this defense was distinct from the justification defense presented by Dupree’s trial counsel.

22009–2009
State v. Castrillo green
nm · 1991
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
People v. Govan green
illappct · 1988
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See State v Padilla, 114 Hawaii 507, 513-514 ; 164 P3d 765 (Hawaii App, 2007) (recognizing a justification defense to being a felon-in-possession if the possession is immediately necessary to protect the defendant or another from serious physical harm); State v Parker, 127 Wash App 352, 354-355; 110 P3d 1152 (2005) (recognizing a necessity defense to felon-in-possession statute and listing elements); People v Jones, 4 Misc 3d 782, 787 ; 781 NYS2d 852 (NY Sup Ct, 2004) (recognizing justification defense for felon-in-possession); Humphrey v Commonwealth, 37 Va App 36, 47-48; 553 SE2d 546 (2001)

22009–2009
People v. Davis green
michctapp · 1983
2 sentences

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

12009–2009
State v. Blache green
la · 1985
1 sentence

2009See Hernandez-Garcia, 477 Mich. at 1040 n. 1, 728 N.W.2d 406 (noting that, in order to be convicted of carrying a concealed weapon, MCL 750.227, the accused must have knowingly possessed the weapon); People v. Davis, 126 Mich.App. 66, 69 , 337 N.W.2d 315 (1983) (noting that, in order to be convicted of carrying or possessing a firearm during the commission of a felony, MCL 750.227b, the defendant must have knowingly possessed the firearm). [3] See State v. Padilla, 114 Hawai`i 507, 513-514, 164 P.3d 765 (Hawai'i App., 2007) (recognizing a justification defense to being a felon-in-possession if

12009–2009
State v. Parker green
washctapp · 2005
12009–2009
Waterford School District v. State Board of Education green
michctapp · 1980
11997–1997
Lucas v. South Carolina Coastal Council green
scotus · 1992
11995–1995
State v. Briley green
nj · 1969
11986–1986
Trammel v. United States green
scotus · 1980
11986–1986
Brewer v. Payless Stations, Inc green
mich · 1982
11983–1983
People v. Dixon green
michctapp · 1978
11983–1983
Watts v. Department of State green
mich · 1975
11983–1983

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 750.317 (5) MI § Mich. Comp. Laws § 750.316 (4) MI § Mich. Comp. Laws § 257.625 (3) MI § Mich. Comp. Laws § 750.227b (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 780 (1925–2026) GA 222 (1978–2026) TX 177 (1958–2026) PA 118 (1979–2026) AZ 86 (1963–2025) CA 73 (1930–2026) IL 57 (1937–2025) IA 49 (1979–2026) AR 33 (1979–2026) OH 32 (1964–2024) NJ 32 (1908–2022) HI 30 (1981–2025) CT 29 (1975–2026) OR 27 (1898–2024) FL 27 (1968–2025) LA 25 (1984–2025) NC 25 (1981–2026) MA 23 (1976–2024) MO 21 (1975–2025) WA 21 (1974–2026) MD 17 (1967–2019) WY 16 (1981–2024) RI 15 (1988–2019) MI 15 (1974–2026) DC 14 (1970–2025) ME 12 (1987–2026) UT 11 (1994–2026) MN 11 (1984–2016) VA 10 (1991–2024) DE 10 (1976–2025) NH 10 (1982–2024) AL 9 (1909–2025) CO 9 (1952–2020) WI 8 (1980–2023) KY 8 (1951–2024) IN 7 (1969–2020) TN 7 (1996–2018) WV 7 (1928–2010) KS 7 (1990–2019) NE 6 (2005–2026) SD 5 (1981–2025) AK 5 (1988–2025) NM 5 (1999–2019) MS 4 (1984–1997) SC 4 (1980–2023) VT 4 (1979–2025) ND 3 (1993–2007) ID 2 (1999–2000) NV 2 (1991–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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