Oklahoma Statutes
Okla. Stat. tit. 21, § 156 (2026)
Duress defense
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A person is entitled to assert duress as a defense if that person committed a prohibited act or omission because of a reasonable belief that there was imminent danger of death or great bodily harm from another upon oneself, ones spouse, or ones child. R.L. 1910, § 2098; Laws 1992, c. 159, § 1, emerg. eff. May 5, 1992.
Notes of Decisions
Cited in 9
cases, 1970–2020 · leading case: Bever v. State, 2020 OK CR 13, 467 P.3d 693.
Bever v. State, 2020 OK CR 13, 467 P.3d 693. “Appellant now seeks to distinguish Long from his case and argues that Long misinterpreted 21 O.S. § 156, regarding the defense of duress, and improperly placed limits on the defense.”
Long v. State, 2003 OK CR 14, 74 P.3d 105. “[7] 21 O.S.2001, §156. [8] 21 O.S.2001, § 156.”
Barnes v. State, 2017 OK CR 26, 408 P.3d 209. “3d at 145 (the defense of duress requires the defendant to have committed a prohibited act or omission because of a reasonable belief that there was imminent danger of death or great bodily harm from another upon oneself, one’s spouse, or one’s child) (quotation and citation…”
Hawkins v. State, 2002 OK CR 12, 46 P.3d 139. “¶ 28 According to 21 O.S.Supp.1992, § 156, duress requires the defendant to have committed a prohibited act or omission "because of a reasonable belief that there was imminent danger of death or great bodily harm from another upon oneself, ones spouse, or ones child.”
Spears v. State, 727 P.2d 96 (Okla. Crim. App. 1986). “Our statute setting forth the defense of duress is 21 O.S.1981, § 156. It does not state against whom the threat of harm must exist.”
Tully v. State, 730 P.2d 1206 (Okla. Crim. App. 1986). “21 O.S.1981, § 156, provides: The duress which excuses a person from punishment who has committed a prohibited act or omission must be an actual compulsion by use of force or fear.”
Denson v. State, 481 P.2d 190 (Okla. Crim. App. 1970). “” Defendant testified that she and her companion, Herbert Hill, dropped into Ro-senfield’s Jewelry Store in Penn Square Shopping Center, Oklahoma City, with no particular objective in mind.”
Smith v. State, 703 P.2d 201 (Okla. Crim. App. 1985). “Title 21 O.S.1981, § 155, provides: The involuntary subjection to the power of a superior which exonerates a person charged with a criminal act or omission from punishment thereof, arises from duress.”
Barnes v. State, 2017 OK CR 26. “3d at 145 (the defense of duress requires the defendant to have committed a prohibited act or omission because of a reasonable belief that there was imminent danger of death or great bodily harm from another upon oneself, one's spouse, or one's child) (quotation and citation…”
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