People v. Goetz
Citation: 497 N.E.2d 41 (N.Y. 1986)
Facts
Bernhard Goetz shot four Black teenagers on a New York City subway after one approached him and asked for five dollars. Goetz, who had been mugged before and was carrying an unlicensed handgun, shot all four — one in the back as he was fleeing — and left one paralyzed. Goetz surrendered to police and gave a detailed confession. A grand jury initially declined to indict; a second grand jury indicted him after the court addressed the correct legal standard.
Issue
Whether New York’s self-defense statute requires a purely subjective inquiry into what the defendant believed, or an objective inquiry into what a reasonable person in the defendant’s situation would have believed.
Holding
The New York Court of Appeals held that New York’s self-defense statute requires an objective standard: the defendant’s belief that force was necessary must be both honest and reasonable. A purely subjective standard — asking only whether the defendant genuinely believed he was in danger — was rejected.
Rule
Self-defense justification requires that the defendant’s belief in the necessity of using force be reasonable as measured by what a reasonable person in the defendant’s situation (including relevant prior experiences) would have believed, not merely that the defendant subjectively believed it.
Significance
Goetz is the seminal case on objective versus subjective self-defense standards and sparked national debate about race, vigilantism, and the role of prior victimization in shaping “reasonableness.” It is central to understanding how courts calibrate the self-defense standard and the limits of individualized reasonable-person inquiries.