Self-Defense in a Case of Aggravated Battery

           In the case of William Stieh versus the State of Florida, Mr. Stieh was charged with the crime of aggravated battery after stabbing another individual.  The relevant facts of Stieh's case are as follows:

          "Conneally, the victim; the victim's girlfriend; Stieh, . . . ; and Jeffrey Flaherty, [Stieh's] friend—engaged in a consensual sexual encounter.  Conneally and his girlfriend were invited to join Stieh and Flaherty in the hotel room rented by Stieh.  After the three men had sex with Conneally's girlfriend, she and Conneally left the hotel.  Shortly after leaving, the two realized their wallets were missing, and they returned to Stieh's hotel room to search for them.  Upon arriving, Conneally initiated a physical confrontation with Flaherty.  In defense of himself and Flaherty, Stieh stabbed Conneally three times.

          At trial, the [prosecutor] did not contest that the victim was significantly larger in stature than Stieh—at 5 feet 5 inches tall and 130 pounds—and Flaherty—at 5 feet 7 inches tall and 160 pounds.  It was also uncontested that the victim was demeaning, demanding, and aggressive during the sexual encounter prior to the stabbing.  Finally, of the four people directly involved in the incident, only the victim testified that he was not angry upon his return to the hotel.  The other three testified that the victim was angry and that he forced entry into Stieh's hotel room.  The victim, however, testified that he only became angry upon finding the wallets under a trash can outside of the hotel room.  Thus, there was a consensus among the parties and witnesses that the victim either arrived angry and looking for a confrontation or became angry and confrontational after locating the wallets that appeared as though they had been intentionally hidden.

          The victim testified that while he and Flaherty were standing outside of the room, he found the wallets under a trash can.  He became angry and shoved Flaherty back inside the hotel room.  The two fought, the victim shoving Flaherty, and Flaherty punching the victim.  At some point during the skirmish, the victim realized he was bleeding and left the hotel room.  The victim did not testify to a physical altercation with Stieh and did not recall being stabbed.

          After the altercation and stabbing, two law enforcement officers arrived on the scene and interviewed Stieh and Flaherty.  Both officers testified that Stieh admitted stabbing the victim.  Officer Murray stated that Stieh told him he was scared and thought the victim was going to hurt Flaherty.  Stieh also told the officer the victim was 'off the chain.'  Officer Stewart testified Stieh told him that he had left the room after the victim and the victim's girlfriend returned to look for the wallets and that when he returned to the room, the victim was attacking Flaherty.  Stieh then told the officer that the victim charged him, that he told the victim to 'get back,' that the victim charged again, and that Stieh stabbed him.

          [Stieh]presented the testimony of several witnesses, including the victim's girlfriend, Flaherty, and Stieh.  Conneally's girlfriend testified that the victim was angry and yelling when they returned to the hotel.  She stated the victim punched and shoved both Flaherty and Stieh. Although she did not see the actual stabbing, she testified she did see the victim and Stieh standing face to face.

          Flaherty testified the victim was screaming that he was going to kill both Stieh and Flaherty for stealing the wallets.  He stated the victim attacked him and dragged him from his bed.  Flaherty yelled for Stieh's help, and Stieh attempted to separate the victim and Flaherty.  According to Flaherty, the victim then threw Stieh around the room and up against the door.  At some point, the victim forced Stieh out of the room, and Flaherty did not see the stabbing.

          Stieh testified the victim returned to the hotel screaming and threatening to kill Stieh. He confirmed Flaherty's account of the events, adding that he attempted to leave the hotel room but was caught by the victim and they exited the room together.  Stieh testified that upon seeing the wallets in the hallway, the victim yelled that he was going to kill them.  Stieh again tried to escape, this time back into the room, but the victim caught him.  The victim attempted to punch Stieh, and Stieh picked up a knife from the dresser and stabbed the victim.  Stieh testified he was scared for his life."

          After Stieh had presented all of his evidence, Stieh's lawyer asked the judge to find Stieh not guilty because the prosecutor had failed to disprove Stieh's theory of self-defense.  The judge did not do so, and Stieh was ultimately convicted of aggravated battery.

          On appeal, Florida's Second District Court of Appeal stated that when an accused individual presents a prima facie case of self-defense at his trial, the prosecutor has to prove beyond a reasonable doubt that the accused did not act in self-defense.  If the prosecutor fails to do that, the trial judge must find the accused not guilty.  The Court continued on to state that according to Florida law:

          "A person who is not engaged in an unlawful activity and who is attacked in any other place where he or she has a right to be has no duty to retreat and has the right to stand his or her ground and meet force with force, including deadly force if he or she reasonably believes it is necessary to do so to prevent death or great bodily harm to himself or herself or another or to prevent the commission of a forcible felony.

          The legal presumption that a defendant has a reasonable fear of great bodily harm sufficient to justify the use of deadly force applies when

[t]he person against whom the defensive force was used was in the process of unlawfully and forcefully entering, or had unlawfully and forcibly entered, a dwelling, residence, or occupied vehicle, or if that person had removed or was attempting to remove another against that person's will from the dwelling, residence, or occupied vehicle."

          The Second District Court of Appeal noted that in Stieh's case:

          1.  Stieh had a right to be in the hotel room because he had lawfully rented the room for the night;

          2.  Under Florida law, the hotel room qualified as a dwelling or residence;

          3.  Only one witness, the victim Conneally, testified that he did not forcibly enter the hotel room in search of the wallets. However, three other witnesses testified that Conneally forcibly removed Stieh from the room at one point during the altercation.  Therefore, under Florida law, Stieh had a right to defend himself;

          4.  Furthermore, two of the prosecutor's witnesses supported Stieh's self-defense argument when they testified that immediately after the stabbing, Stieh told them that he was acting in defense of Flaherty.  The Court observed that defense of another person is permitted under Florida law.

          The appellate court concluded that because the prosecutor failed to present legally-sufficient evidence to overcome Stieh's theory of self-defense, the lower-court judge should have found him not guilty of aggravated battery.  Accordingly, the Second District Court of Appeal sent Stieh's case back to the lower court with instructions that Stieh should be found not guilty.