AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant, Douglas Hodgman, was convicted of battery against a household member, his estranged wife, Jolena Hodgman. The incident occurred after the Defendant discovered that the Victim had withdrawn money from their business account without his knowledge, leading him to freeze the account. Following this, the Victim confronted the Defendant at their jointly owned motorcycle shop, where he pushed her out of his office and locked the door. The Defendant claimed he acted in self-defense, fearing the Victim might be armed based on previous emails she sent him about purchasing a gun (paras 3-5, 7-8).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• • Defendant: Argued that his conviction should be reversed and the case remanded for a new trial on the grounds that the district court erred in denying his request for a self-defense jury instruction. He contended that there was sufficient evidence to support a self-defense instruction, citing his fear that the Victim might be armed and his actions were in response to this fear (paras 1, 6).
• • Plaintiff-Appellee (State): Conceded that the Defendant adequately preserved the self-defense issue for appeal but argued against the necessity of a self-defense instruction based on the circumstances of the case (para 13).

Legal Issues

• Whether the district court erred in denying the Defendant's request for a self-defense jury instruction.

Disposition

• The Court of Appeals reversed the Defendant's conviction for battery against a household member and remanded for further proceedings consistent with the opinion (para 21).

Reasons

• The Court, led by Judge Michael D. Bustamante with Judges Jonathan B. Sutin and Michael E. Vigil concurring, found that the evidence presented at trial supported the Defendant's request for a self-defense instruction. The Court reasoned that the Defendant's subjective fear of immediate bodily harm, based on the Victim's previous communications about purchasing a gun and her aggressive confrontation, warranted consideration of self-defense. The Court determined that whether the Defendant's actions were reasonable under the circumstances was a question for the jury. Despite the Defendant's admission that he did not see the Victim with a gun at the time of the incident, the Court concluded that the jury should have been allowed to decide the reasonableness of his response based on his perceived threat. The decision to reverse was based on the principle that a defendant is entitled to a jury instruction on his theory of the case if there is evidence to support the instruction, and failure to give such an instruction is reversible error (paras 13-20).