Bechtel v. State, 840 P.2d 1 (Okla. Crim. App. 1992)

Facts: Donna Bechtel married Ken Bechtel in 1982. Her husband perpetrated approximately 23 violent batterings over two years—repeatedly grabbing her by the hair or ears and pounding her head against walls/objects, often when intoxicated. After a particularly brutal sexual assault, while sitting on the floor lighting a cigarette, she heard Ken make a gurgling sound, looked up, saw his "contorted look and glazed eyes" with arms raised, reached for a gun under the bed, and shot him as she tried to flee. Defended on theory of self-defense.
Issue: Whether Bechtel could claim self-defense given the battered-woman context, and whether the trial court erred in refusing a "no duty to retreat" instruction.
Rule: Deadly force in self-defense is justified if ∆ believed it necessary to protect herself from imminent danger of death or great bodily harm, AND reasonable grounds existed for that belief. Courts may consider expert testimony on battered-woman syndrome to inform the reasonableness of ∆'s perception of imminence.
Analysis: A battered woman's perception, given her particular circumstances, may be reasonable even if it would not be to a "calm mind." She may justifiably act during a lull or before the violence escalates. The issue is not whether danger was actually imminent but whether ∆'s belief was reasonable in her circumstances. Court's pattern instructions on duty to retreat were adequate.
Judgment: Reversed and remanded for new trial.

Reading: pp. 605–15. See Self-Defense (battered-defendant doctrine).