## Facts

- W.J.B., a juvenile, shot and killed Michael Watson (age 21) inside W.J.B.’s family home on February 19, 1979.
- Watson had a documented pattern of violent conduct toward W.J.B. and his family connected to Watson’s relationship with W.J.B.’s 15-year-old sister, including prior attacks in the home and the mother’s obtaining multiple arrest warrants against Watson.
- On the night of the killing, Watson (apparently intoxicated) forcibly broke into the home, chased the sister, and left only after learning police had been called; officers responded and then departed.
- After police left, Watson returned outside the home, shouted threats, threw objects, and was observed with a butcher knife.
- W.J.B. retrieved a shotgun and waited in the living room.
- Watson kicked open the living room door a second time, continued threatening behavior, and advanced toward W.J.B.
- W.J.B., seated, fired one shot, killing Watson; police found a knife in Watson’s hand under his body.
- The circuit court denied the State’s motion to transfer the case to adult criminal jurisdiction and, after an adjudicatory hearing, found W.J.B. committed voluntary manslaughter and adjudicated him delinquent.
- W.J.B. appealed, arguing the evidence was insufficient because the State did not negate self-defense beyond a reasonable doubt.

## Issues

1. Whether the evidence was sufficient to support a juvenile adjudication for voluntary manslaughter when the juvenile presented substantial evidence of self-defense during a violent home intrusion.
2. Whether an occupant attacked in his dwelling may use deadly force against an unlawful intruder without retreating when the intruder threatens imminent physical violence or the commission of a felony.
3. Whether, once self-defense evidence creates a reasonable doubt, the prosecution must prove beyond a reasonable doubt that the defendant did not act in self-defense.

## Decision

- The Supreme Court of Appeals of West Virginia reversed the adjudication for voluntary manslaughter.
- The court held the evidence, viewed under the governing self-defense rules for a dwelling occupant, created at least a reasonable doubt that W.J.B. acted in self-defense.
- Because self-defense was sufficiently in issue, the State bore the burden to disprove self-defense beyond a reasonable doubt and failed to meet that burden.

## Legal Principles

- An individual attacked in his own home by an intruder may claim self-defense without a duty to retreat.
- A dwelling occupant is not limited to using deadly force only when threatened with death or serious bodily injury; deadly force may be used if the unlawful intruder threatens imminent physical violence or the commission of a felony and the occupant reasonably believes deadly force is necessary.
- Reasonableness is judged from the actor’s standpoint at the time of the घटना and is not measured by later-developed facts.
- Once evidence is sufficient to create a reasonable doubt that a killing was in self-defense, the prosecution must prove beyond a reasonable doubt that the defendant did not act in self-defense.

## Conclusion

The court set aside the juvenile voluntary manslaughter adjudication because the largely undisputed evidence of a violent, armed, repeat home intrusion established at least reasonable doubt that the shooting was justified, and the State did not disprove self-defense beyond a reasonable doubt under West Virginia’s dwelling-occupant rules.


State v. W.J.B., 276 S.E.2d 550 (W. Va. 1981)