## Facts

- The United States prosecuted federal prisoners Ronald Boyd Slocum, Wayne Bridgewater, and Henry Michael Houston in a large Aryan Brotherhood (AB) prison‑gang case that included homicide-related charges tied to events at USP Lewisburg in Pennsylvania.
- Bridgewater and Houston were AB members and were accused of stabbing to death two fellow inmates affiliated with a rival group, the D.C. Blacks, during a broader conflict between the AB and the D.C. Blacks.
- Evidence at trial described Bridgewater as a longtime and influential AB member; evidence also indicated Houston had been associated with the AB for years and was made a member shortly before the attacks.
- The government’s evidence indicated the two victims were unarmed and in nonaggressive stances when they were stabbed.
- The record contained no evidence that either victim had previously attacked or threatened Bridgewater or Houston.
- Before the case went to the jury, the government moved to preclude any duress defense and requested that the jury be instructed that duress was unavailable.
- Bridgewater requested a jury instruction on self-defense (and related defensive theories), contending the stabbings occurred against the backdrop of a dangerous gang war in which AB inmates faced lethal threats.
- Houston requested jury instructions on self-defense, defense of others, and imperfect self-defense on similar grounds.

## Issues

1. Whether the evidence was sufficient to permit Bridgewater and Houston to argue self-defense (and related defensive theories) and to receive jury instructions on self-defense, defense of others, or imperfect self-defense for the charged stabbings.
2. Whether the evidence was sufficient to permit a duress defense and a duress jury instruction, or whether duress should be precluded.

## Decision

- The court granted the government’s motion in limine to preclude a duress defense and declined to instruct the jury on duress.
- The court denied Bridgewater’s request for a self-defense instruction.
- The court denied Houston’s requests for instructions on self-defense, defense of others, and imperfect self-defense.
- The court ruled that the evidentiary record did not support required elements of these defenses, especially an imminent threat and the necessity for deadly force.

## Legal Principles

- A criminal defendant is entitled to a requested theory-of-defense instruction only when there is evidence from which a reasonable jury could find each essential element of that defense.
- Duress in federal criminal cases generally requires proof of: (1) an immediate threat of death or serious bodily injury, (2) a well-grounded fear the threat will be carried out, and (3) no reasonable opportunity to escape or avoid the threatened harm.
- General fear of prison violence or gang retaliation, without a specific and immediate coercive threat tied to the charged act, is insufficient to submit duress to the jury.
- Self-defense and defense of others require evidence that the defendant actually believed he (or another) faced imminent death or serious bodily injury, that the belief was objectively reasonable, and that the force used was no more than reasonably necessary.
- Imperfect self-defense requires at least an honest belief in imminent danger (even if unreasonable); without evidence supporting such a belief at the time of the killing, the instruction is unwarranted.

## Conclusion

United States v. Slocum held that Bridgewater and Houston were not entitled to jury instructions on duress, self-defense, defense of others, or imperfect self-defense where the trial record showed the victims were unarmed and nonaggressive and contained no evidence of prior attacks or specific imminent threats by the victims that could make lethal force necessary or excuse the stabbings based on coercion.


United States v. Slocum, 486 F. Supp. 2d 1104 (2007)