ARRESTED
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Understanding Minnesota’s New Law on Defense of Another: A Closer Look at the State vs. Valdez Case

Oct 17, 2024 | Firm News, General Blogs

In a significant development, the Minnesota Supreme Court has clarified an important aspect of criminal defense law: the defense of another. This decision has profound implications for how Minnesotans may protect others from harm without facing legal consequences. Defense attorney Ryan Pacyga recently discussed this topic, referencing both a case he defended 15 years ago and the Supreme Court’s ruling in State vs. Valdez to explain the current legal landscape.

A Case of Family Protection: Defending Another from Attackers

Pacyga recalled a case from about 15 years ago that illustrates how the defense of another can be used in court. In this instance, a young man was targeted by a group of armed individuals, and his older brother stepped in to defend him. The attackers, armed with clubs, chains, and baseball bats, posed a serious threat. To protect his sibling, the older brother grabbed a bat and fought off the attackers.

Despite his good intentions, the older brother was charged with first-degree criminal assault. Pacyga mounted a defense based on the principle of defending another person, which is an established legal right. However, a critical question arose during the trial: Did the older brother have a duty to retreat before using force to protect his younger brother?

At that time, Minnesota law was unclear on whether the duty to retreat applied when defending someone else. The prosecutor and the judge believed the law suggested such a duty, but Pacyga argued that it was illogical in this context. Ultimately, the jury found the older brother not guilty, ruling in favor of the defense of another.

The Duty to Retreat: Clarified by the Minnesota Supreme Court in State vs. Valdez

While Pacyga’s case ended in a favorable verdict, the law regarding the duty to retreat when defending another remained unclear for years. This changed with the State vs. Valdez case, which addressed two critical questions:

  1. Does a defendant have a duty to retreat when defending another person?
    The court’s answer was no. The ruling clarified that if you are protecting someone else, you are not obligated to retreat before using force. This represents a shift from previous jury instructions that suggested defenders might be required to retreat in such situations.
  2. Must the defendant determine if the person in danger could have retreated?
    The answer was more nuanced. The court ruled that the defendant does not need to assess the situation from the perspective of the person in peril, but they do need to consider whether retreat was an obvious option based on what they saw, heard, and knew at the time of the incident.

Ultimately, it is difficult to apply this rule in real-world situations, particularly when defenders must make split-second decisions under duress. In many cases, it’s unrealistic to expect someone to assess whether the person they are protecting can retreat while facing an immediate threat.

The Complexity of Split-Second Decisions

A key concern with the Supreme Court’s ruling is the practicality of these requirements. In dangerous situations, such as when an assailant draws a gun, defenders often have only seconds to act. Pacyga emphasized that expecting someone to carefully evaluate whether the person in peril could retreat before using force is impractical. In scenarios where there’s an immediate danger, such as a gun being drawn, defenders must act quickly, and split-second decisions may not allow time for such assessments.

How Does This Affect You?

The State vs. Valdez case has far-reaching implications for anyone who may find themselves defending another person from harm. The law now clearly states that you are not obligated to retreat when protecting someone else. However, to justifiably use force in defense of another a defendant must believe that the person in danger has no reasonable possibility of safe retreat, and the defendant’s belief must be objectively reasonable based on the information available to the defendant at the time that they use force to defend the person in danger. 

Have questions about the defense of another? Contact us for a consultation. We’re here to protect your rights and offer guidance through these challenging legal waters.

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