defendant cannot claim in District of Columbia

2016See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, "a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defendant who voluntarily—knowingly and unnecessarily—placed himself in a position where he had reason to believe his presence would provoke the violence from which he then found it necessary to

2016Thus, to defeat appellant’s claim of self-defense and secure a conviction, the government needed to disprove at least one of the four aforementioned conditions beyond a reasonable doubt.7 6 See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, “a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defe

2016See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, "a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defendant who voluntarily—knowingly and unnecessarily—placed himself in a position where he had reason to believe his presence would provoke the violence from which he then found it necessary to

2016Thus, to defeat appellant’s claim of self-defense and secure a conviction, the government needed to disprove at least one of the four aforementioned conditions beyond a reasonable doubt.7 6 See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, “a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defe

2016See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, "a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defendant who voluntarily—knowingly and unnecessarily—placed himself in a position where he had reason to believe his presence would provoke the violence from which he then found it necessary to

2016Thus, to defeat appellant’s claim of self-defense and secure a conviction, the government needed to disprove at least one of the four aforementioned conditions beyond a reasonable doubt.7 6 See Swann v. United States, 648 A.2d 928 , 930 n.7 (D.C. 1994) (noting that even when the other conditions of a self-defense claim are satisfied, “a defendant cannot claim self-defense if the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself”) (internal quotation marks omitted); see also Andrews, 125 A.3d at 321 (“A legitimate claim of self-defense is not available to a defe

2016See Swann, 648 A.2d at 930-33 ; see also Richardson, 98 A.3d at 187 n.11.

2008Robinson v. United States, 649 A.2d 584, 587 (D.C.1994).

1996See Payne v. Soft-Sheen Prod., 486 A.2d 712 , 721 n. 9 (D.C.1985). 19 In sum, under either the per se or strict liability theories, the plaintiff must establish the applicable standard of care, show that the defendant violated that standard, and that the violation was the proximate cause of the injury.

1994Comber v. United States, 584 A.2d 26, 41 , 42 n. 19 (D.C.1990) (en banc); Davis v. United States, 510 A.2d 1051, 1053 (D.C.1986) (per curiam). [7] Even in such circumstances a defendant cannot claim self-defense if "the defendant was the aggressor, or if s/he provoked the conflict upon himself/herself." CRIMINAL JURY INSTRUCTIONS, supra, No. 5.16. [8] As Comber points out, the distinction between the two concepts can become a bit murky.