State v. Grannis

In State v. Grannis, 183 Ariz. 52, 900 P.2d 1 (1995), the trial court had instructed the jury that "a defendant may only use deadly physical force in self-defense to protect himself from another's use or attempted use of deadly physical force." On appeal, the supreme court found that the instruction misstated the law because it may have led the jury to believe that deadly force could be used only to protect against "actual deadly force" even though 13-404 and -405 also allow deadly force to protect against "reasonably apparent deadly force." Id.