Rajnic v. State

In Rajnic v. State, 106 Md. App. 286, 664 A.2d 432 (1995), the defendant went into his bedroom during a party, and placed a handgun kept by his girlfriend onto a dresser. 106 Md. App. at 291. When four men at the party threatened to attack him for allegedly striking his girlfriend, Rajnic returned to his bedroom and closed the door. Three of the men eventually charged into the bedroom. During the melee that followed, three men were shot and killed. 106 Md. App. at 292. The Court concluded in Rajnic that, according to Gunther, the trial court should have instructed the jury "that one who is not the aggressor but has reason to fear an attack upon his life does not forfeit his right to self-defense by arming himself in advance of the attack." 106 Md. App. at 295. The Court disapproved, however, of the use of language declaring a defendant's "right to arm himself in anticipation of an assault." 106 Md. App. at 295-96. The Court instructed the jury that in order to find that appellant acted in self-defense, it must find that he "actually believed he was in immediate and imminent danger of death or serious bodily harm" and that this belief was "reasonable." Rajnic, 106 Md. App. at 296. There, the Court found reversible error because the language "did not include the thought that the defendant's belief had to be reasonable in view of the circumstances as they appeared to the defendant at the time." 106 Md. App. at 297.