Fill and Sign the Jury Instructions Form

STATE OF LOUISIANA : ______ JUDICIAL DISTRICT COURT VS : PARISH OF ______ , LOUISIANA ________________ : DOCKET NO. ______ DEFENDANT = S REQUESTED JURY INSTRUCTIONS I. The Defendant does not bear the burden of proving self-defense in a nonhomicide case. Rather, the state must prove beyond a reasonable doubt that the Defendant did not act in self defense. State v. Fluker, 618 So.2d 459 (La.App.4 Cir. 1993). II. The issue of self-defense in nonhomicide instances requires a dual inquiry: (1) an objective inquiry into whether the force used was reasonable under the circumstances and (2) a subjective inquiry into whether the force was apparently necessary. State v. Anderson , 721 So.2d 1006 (La.App. 3 Cir. 1998). III. Evidence of the victim = s dangerous character or threats against the Defendant are relevant to a plea of self-defense for the purpose of showing the Defendant = s reasonable apprehension of danger which would justify his conduct and to show the victim was the aggressor. State v. Ford , 368 So.2d 1074 (La.1979); State v. Collins , 432 So.2d 369 (La.App. 1 Cir. 1983). Respectfully Submitted, __________________________ ________________ ______ Parish I.D. Board ______ , LA ______ ( ___ ) ______ CERTIFICATE I HEREBY CERTIFY that the above and foregoing has been forwarded to all opposing counsel by hand delivering a copy of same. ________________ , Louisiana, this _____ day of __________ 20 ___ . __________________________ ________________