DOMINIQUE BASSIL v. UNITED STATES
147 A.3d 303
| D.C. | 2016Background
- Dominique Bassil stabbed and killed her boyfriend, Vance Harris, in their apartment in the early morning of August 13, 2011; she claimed she acted in self-defense.
- No other eyewitnesses to the stabbing existed; Bassil was the sole eyewitness and consistently asserted she stabbed to save herself.
- Prosecution presented relationship history (jealousy, threats in texts, wedding incident where Bassil slapped Harris), contemporaneous statements, and physical evidence to show motive and contradict Bassil’s account.
- Physical evidence: two deep stab wounds (abdomen and arm), defensive wounds on Harris, an 8.5" kitchen knife, surveillance showing Bassil discarding a knife, and lack of injuries on Bassil inconsistent with her account of being beaten.
- Bassil made multiple pretrial statements to police describing an assault, but at trial she changed or minimized several details; the jury convicted her of second-degree murder while armed.
Issues
| Issue | Plaintiff's Argument (Bassil) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Sufficiency of evidence to disprove self-defense | Bassil: No witness or evidence contradicts her self-defense account; jury disbelief alone cannot establish the opposite fact. | Govt: Circumstantial evidence, motive, contradictions, and false exculpatory statements permit a rational jury to find she did not act in self-defense. | Court: Affirmed conviction; evidence sufficient to disprove self-defense beyond a reasonable doubt. |
| Whether jury may infer guilt from disbelief of defendant’s testimony | Bassil: Mere disbelief of testimony cannot be used as exclusive proof of contrary facts. | Govt: Disbelief coupled with internal inconsistencies, prior inconsistent statements, and evidence of consciousness of guilt can support an inference of falsity and guilt. | Court: Disbelief may support guilt inference in limited circumstances (e.g., demonstrable lies, internal implausibility, or corroborating evidence); here such circumstances existed. |
| Objective reasonableness of fear and necessity of deadly force | Bassil: She honestly believed deadly force was necessary to prevent imminent harm. | Govt: Evidence showed Harris was unarmed, had not seriously injured her previously, Bassil could have fled, and her account of events was implausible—so belief was not objectively reasonable. | Court: A reasonable jury could find her fear and use of deadly force objectively unreasonable. |
| Role of motive and false statements in assessing self-defense | Bassil: Her statements are exculpatory and should not be the sole basis for conviction. | Govt: Threatening texts, relationship history, discrepant statements, and demonstrable falsehoods indicate motive and consciousness of guilt. | Court: Motive evidence plus false/exaggerated statements supported the jury’s finding that Bassil lied and was not acting in self-defense. |
Key Cases Cited
- Comber v. United States, 584 A.2d 26 (D.C. 1990) (defines malice aforethought and burden to disprove justification)
- Rivas v. United States, 783 A.2d 125 (D.C. 2001) (Jackson sufficiency standard and deference to jury credibility determinations)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
- Evans-Reid v. District of Columbia, 930 A.2d 930 (D.C. 2007) (limits on drawing appellate-reviewable inferences from witness demeanor and testimony)