Katrell A. Henry v. United States, 94 A.3d 752

Appellant Katrell Henry was tried for murder and related firearms offenses tied to a 2010 shooting of Laroy Bryant; the jury acquitted murder but convicted manslaughter and all firearm counts.
Appellant testified he did not shoot Bryant and that any shooting targeted Bryant’s associates; he claimed self-defense only against the dumpster shooters, not Bryant.
The defense requested a self-defense instruction covering Bryant, arguing a group-threat theory; the court declined to give it for Bryant.
The jury heard Nelson’s testimony about the shooting sequence and notes appellant fired after being shot at by others near dumpsters.
The trial court instructed self-defense only as to shots aimed at the dumpster group, not at Bryant; defense argued the record supported broader self-defense instruction.
Appellant challenges the denial of the self-defense instruction as to Bryant on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of self-defense instruction as to Bryant was reversible error	Henry argues evidence supported belief Bryant threatened him	Henry contends group threat via Bryant justified self-defense	No reversible error; no sufficient evidence Bryant was armed or that Henry reasonably believed imminent deadly threat from Bryant
Whether the court properly applied standards for self-defense instructions	Evidence could show immediate peril from Bryant or group	No evidence Bryant was armed or posed imminent danger to Henry	Court correctly limited self-defense instruction to shots directed at the dumpster group, not at Bryant
Whether the defense theory supported by evidence required a broader instruction	Defense theory of group-based self-defense could negate guilt	Record lacked basis that Bryant posed imminent threat	Insufficient facts to justify broader self-defense instruction for Bryant

Higgenbottom v. United States, 923 A.2d 891 (D.C. 2007) (defense instruction required when supported by any evidence)
Gray v. United States, 549 A.2d 347 (D.C. 1988) (instruction must reflect defense theory even if weak)
Harper v. United States, 608 A.2d 152 (D.C. 1992) (elements of self-defense—immediate peril and necessity)
Edwards v. United States, 721 A.2d 938 (D.C. 1998) (group-attack scenarios and weapon visibility affect instruction)
Murphy-Bey v. United States, 982 A.2d 682 (D.C. 2009) (reversible error for failure to give defense instruction negating guilt)
United States v. Peterson, 483 F.2d 1222 (D.C. Cir. 1973) (necessity and imminence in self-defense)
Rajnic v. State, 664 A.2d 432 (Md. 1995) (group threats and self-defense principles)
Wilson v. United States, 673 A.2d 670 (D.C. 1996) (self-defense instruction warranted where record supports claimed defense)
Reid v. United States, 581 A.2d 359 (D.C. 1990) (played with knives scenario—self-defense instruction considerations)