David Stanfield v. State of Mississippi, 269 So. 3d 1188

On Feb. 18, 2015, David Stanfield was at a house where gunfire injured three people; conflicting testimony whether Stanfield was aggressor or acting in self‑defense.
Stanfield was indicted for three counts of aggravated assault and one count of felon in possession of a firearm; he stipulated to a prior felony conviction.
At trial the court instructed the jury on self‑defense (for the assault counts) and gave Stanfield a necessity instruction (C‑7) for the felon‑in‑possession charge.
The court also gave Instruction S‑6: "self‑defense is not a viable defense to possession of a firearm by a convicted felon," over Stanfield’s objection that it conflicted with the necessity instruction.
Jury convicted Stanfield of one aggravated assault and felon in possession; he appealed, arguing the S‑6 instruction improperly negated his self‑defense theory insofar as it related to necessity for temporary possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether jury instruction stating self‑defense is not a defense to felon‑in‑possession conflicted with a necessity instruction and thus was erroneous	Stanfield: self‑defense is part of necessity here (temporary possession to avoid bodily harm); S‑6 deprived him of his theory and confused jury	State: self‑defense and necessity are distinct; felon‑in‑possession is a victimless crime and self‑defense is not a defense to the possession element; necessity instruction adequately covered defendant’s theory	Court affirmed: no abuse of discretion. Self‑defense is not a defense to felon‑in‑possession; necessity is separate and must be proven by defendant

Williams v. State, 953 So. 2d 260 (Miss. Ct. App. 2006) (rejecting self‑defense exception to felon‑in‑possession; possession is victimless crime)
Thomas v. State, 249 So. 3d 331 (Miss. 2018) (standard: jury instruction review is abuse of discretion)
Newell v. State, 49 So. 3d 66 (Miss. 2010) (instructions read as whole; no reversible error if law fairly announced)
Heidel v. State, 587 So. 2d 835 (Miss. 1991) (absence of self‑defense may be treated as element of some crimes; State bears burden)
Humphrey v. Commonwealth, 553 S.E.2d 546 (Va. Ct. App. 2001) (necessity can justify felon’s temporary possession for self‑defense)