State v. Bass, 371 N.C. 535

On July 4, 2014 Justin Bass shot Jerome Fogg after an earlier June 23 altercation in which Fogg severely beat Bass and broke his jaw; Bass claimed self-defense.
Bass was indicted for attempted first-degree murder and assault with a deadly weapon; convicted of assault with a deadly weapon inflicting serious injury and sentenced to 30–48 months.
At trial Bass claimed self-defense and the defense requested "no duty to retreat" (stand‑your‑ground) jury instructions; the trial court denied the full instruction.
The trial court excluded testimony about specific prior violent acts by Fogg, allowing only reputation/opinion evidence of violent character.
On the eve of trial the State disclosed five new incidents involving Fogg; defense moved for a continuance to investigate and the trial court denied the motion.
The Court of Appeals granted a new trial on three grounds (jury instruction omission; exclusion of specific‑act evidence; denial of continuance). The Supreme Court reviewed the appeal.

Issue	State's Argument	Bass's Argument	Held
Whether omission of the full "no duty to retreat" (stand‑your‑ground) language from the self‑defense jury charge was reversible error	Trial court correctly omitted because Bass was not in home/work/vehicle	Bass entitled to complete self‑defense instruction including place the defendant had a lawful right to be	Reversible error: omission of stand‑your‑ground language required new trial (Lee controls)
Whether trial court erred excluding evidence of specific prior violent acts by victim under Rule 405(b)	Exclusion proper: victim's prior violent character admissible only by reputation/opinion, not specific acts	Specific prior acts relevant to show victim was first aggressor	Affirmed exclusion: specific‑acts inadmissible because victim's character is not an "essential element" of self‑defense
Whether denial of continuance to investigate newly disclosed incidents of victim's conduct was error	Denial proper because the additional evidence would have been inadmissible	Continuance necessary to investigate potential admissible evidence and impeach credibility	Affirmed denial: motion aimed at developing evidence that would be inadmissible, so no abuse of discretion

State v. Lee, 370 N.C. 671, 811 S.E.2d 563 (N.C. 2018) (omission of stand‑your‑ground language from self‑defense charge is reversible error)
State v. Watson, 338 N.C. 168, 449 S.E.2d 694 (N.C. 1994) (victim's violent character may be shown by opinion/reputation when self‑defense at issue)
State v. Norris, 303 N.C. 526, 279 S.E.2d 570 (N.C. 1981) (elements of self‑defense include that defendant was not the aggressor)
United States v. Bordeaux, 570 F.3d 1041 (8th Cir. 2009) (victim's violent character is not an essential element of self‑defense; specific‑act evidence excluded)
United States v. Jackson, 549 F.3d 963 (5th Cir. 2008) (prison records and specific violent incidents inadmissible under Rule 405(b) to prove victim was first aggressor)