State of Minnesota v. Susan Patrice Long, A15-2095

Susan Patrice Long stabbed C.T. during an altercation in her apartment and was charged with second-degree assault; she claimed self-defense.
Long and C.T. gave conflicting accounts: Long said she was pushed and feared for her safety; C.T. said Long grabbed a knife and assaulted him while he attempted to leave.
The district court instructed the jury on self-defense, emphasizing that force must be used to avert bodily injury, that belief must be reasonable, force must not be excessive, and there is a duty to retreat if reasonably possible (no duty to retreat at home).
At the close of trial the court reiterated and refined these points and explained aggressor-withdrawal rules for regaining self-defense rights.
Long did not object to the jury instructions at trial and was convicted; she appealed arguing the instructions erroneously limited self-defense to resisting injurious conduct rather than the statutory phrase "offense against the person."
The Court of Appeals reviewed for plain error and affirmed, finding the instructions consistent with Minnesota law and the pattern instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury instructions misstated self-defense law by requiring threat of bodily injury ("bodily injury" vs "offense against the person")	Long: Instructions improperly limited self-defense to resisting injurious conduct and deviated from statutory language and caselaw allowing defense to non-injurious "offense against the person."	State: Instructions fairly captured the elements of self-defense (reasonable belief of imminent bodily harm, reasonable force, duty to retreat except at home) and followed pattern language; court has discretion in wording.	Court: No plain error. Instructions matched governing standards (Devens, CRIMJIG) and were not materially misleading; conviction affirmed.

State v. Cross, 577 N.W.2d 721 (Minn. 1998) (failure to object to jury instructions generally waives appellate review except for plain error)
State v. Gunderson, 812 N.W.2d 156 (Minn. App. 2012) (review of unobjected-to jury instructions under plain-error standard)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (appellate discretion to address unpreserved errors for fairness and integrity)
State v. Ramey, 721 N.W.2d 294 (Minn. 2006) (definition of plain error as contravening case law, rule, or standard)
State v. Devens, 852 N.W.2d 255 (Minn. 2014) (self-defense elements: absence of provocation, honest belief of imminent bodily harm, reasonable grounds, absence of reasonable retreat)
State v. Soukup, 656 N.W.2d 424 (Minn. App. 2003) (self-defense not offense-specific; applies where conduct presents threat of bodily harm)
State v. Gatson, 801 N.W.2d 134 (Minn. 2011) (trial courts have latitude in selecting jury-instruction language)