## Facts

- Janice Leidholm and her husband, Chester, spent August 6, 1981 drinking heavily and arguing at their farmhouse near Washburn, North Dakota.
- During the dispute, Chester shoved and pushed Janice and prevented her from using the phone to contact law enforcement.
- After they went to bed and Chester fell asleep, Janice went to the kitchen, obtained a butcher knife, returned to the bedroom, and stabbed him.
- Chester died within minutes from shock and blood loss.
- Janice was charged with murder and asserted self-defense, supported by expert testimony concerning battered woman syndrome.
- A jury convicted Janice of manslaughter; the trial court imposed a five-year sentence with three years suspended.
- Janice appealed, challenging the self-defense instructions and the court’s refusal to give a specific instruction addressing battered woman syndrome evidence.

## Issues

1. Whether self-defense requires the jury to evaluate the reasonableness of the defendant’s belief in the necessity of force from the defendant’s standpoint, considering circumstances as the defendant reasonably perceived them, rather than by a predominantly objective “reasonably prudent person” standard.
2. Whether the trial court was required to give a separate instruction expressly linking battered woman syndrome expert testimony to the jury’s evaluation of self-defense.

## Decision

- The North Dakota Supreme Court reversed the manslaughter conviction and remanded for a new trial.
- The court held that the trial court misstated the law of self-defense by framing the inquiry in largely objective terms (a “reasonably prudent person” formulation) rather than from the standpoint of the accused as she reasonably perceived the circumstances.
- The court indicated that battered woman syndrome is not an independent defense and that a separate syndrome instruction is not required if the jury is properly instructed to consider all relevant circumstances and evidence bearing on the defendant’s perceptions and their reasonableness.
- Because the erroneous self-defense instruction was dispositive, the court did not resolve all remaining claims of error.

## Legal Principles

- Under North Dakota justification law, the factfinder must assess defensive force based on the defendant’s actual belief, evaluated in light of the circumstances as the defendant reasonably perceived them at the time.
- The self-defense inquiry is subjective in viewpoint (the defendant’s standpoint) but retains a reasonableness constraint (the belief and perceptions must be reasonable in light of the perceived circumstances).
- A purely objective “reasonable person” approach that disregards the defendant’s experiences and situation misstates the governing standard where the statute turns on what the actor “reasonably believes.”
- Expert testimony concerning battered woman syndrome may be considered as part of the totality of circumstances bearing on the defendant’s perceptions and the reasonableness of the defendant’s belief that force was immediately necessary, but it does not create a distinct legal defense requiring a stand-alone instruction.

## Conclusion

The court ordered a new trial because the jury’s self-defense determination must be made from the defendant’s standpoint, considering the circumstances as the defendant reasonably perceived them, and the trial court’s objective-leaning instruction risked applying an incorrect legal standard to the central justification issue.


State v. Leidholm, 334 N.W.2d 811 (N.D. 1983)