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Darby v. State, 383 So.3d 691

Facts

On April 3, 2018, Jeffrey Parker called 911 threatening suicide while holding what appeared to be a gun to his head. Officers Genisha Pegues and Justin Beckles arrived at the scene, where Pegues attempted to de-escalate the situation. Darby, responding to the call, arrived armed with a shotgun and commanded Pegues to point her gun at Parker. Despite the officers' commands, Parker did not comply, and Darby shot him, believing he posed an imminent threat.

On April 3, 2018, Parker telephoned emergency 911 from his residence and “threaten[ed] to … blow his head off” (R. 595), so Officers Genisha Pegues and Justin Beckles of the Huntsville Police Department (“HPD”) were dispatched to Parker's residence. When they arrived, Officer Pegues drew her handgun and stepped over the threshold of the front door such that “the left side of [her] body was partially in the door … and … the right side was out towards the porch area.” (R. 605.) While standing partially inside the residence, Officer Pegues saw Parker sitting on a couch with “what look[ed] like a weapon to his head.” (R. 601.) Officer Beckles was on the porch behind Officer Pegues and could not see Parker, but Officer Pegues told him that Parker had “a gun to his head,” and Officer Beckles “radioed that to dispatch” so that other officers who might be responding to the residence would “know that there [was] a gun in play.” (R. 651.) Darby was on duty at that time and was “pretty close” to Parker's residence, so when he “heard Officer Beckles come over the radio” and mention “a guy with a gun … threatening suicide,” he began driving toward the residence to provide assistance. (R. 900.) It would later be determined that Parker was actually holding “a flare gun that had been intentionally painted black” (R. 705), but there is no evidence indicating that any of the officers were aware of that fact.

Issue

Did the trial court err by failing to instruct the jury to evaluate Darby's use of deadly force from the perspective of a reasonable police officer in the same situation?

Did the trial court err by failing to instruct the jury to evaluate Darby's use of deadly force from the perspective of a reasonable police officer in the same situation?

Rule

The reasonableness of an officer's actions in using deadly force must be objectively reasonable judged from the perspective of a reasonable officer on the scene, considering the facts and circumstances confronting them at the time.

The reasonableness of an officer's actions in using deadly force must be objectively reasonable judged from the perspective of a reasonable officer on the scene, considering the facts and circumstances confronting them at the time.

Analysis

The court determined that the trial court's failure to provide the requested jury instruction was reversible error. The evidence presented indicated that a reasonable police officer in Darby's position could have perceived Parker's actions as an imminent threat, thus justifying the use of deadly force. The court emphasized that the jury should have been instructed to evaluate Darby's actions from the perspective of a reasonable police officer.

The court determined that the trial court's failure to provide the requested jury instruction was reversible error. The evidence presented indicated that a reasonable police officer in Darby's position could have perceived Parker's actions as an imminent threat, thus justifying the use of deadly force. The court emphasized that the jury should have been instructed to evaluate Darby's actions from the perspective of a reasonable police officer.

Conclusion

The Court of Criminal Appeals reversed Darby's conviction and remanded the case for a new trial due to the trial court's error in jury instructions.

The Court of Criminal Appeals reversed Darby's conviction and remanded the case for a new trial due to the trial court's error in jury instructions.

Who won?

William Darby prevailed in the appeal because the court found that the trial court's failure to instruct the jury appropriately constituted reversible error.

William Darby prevailed in the appeal because the court found that the trial court's failure to instruct the jury appropriately constituted reversible error.

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