State v. Berriel, 299 P.3d 1133

Berriel was convicted of aggravated assault for stabbing Luis.
Rachel called Berriel claiming Luis had been hurting her and asked him to come help.
Berriel and several friends drove to Rachel and Luis’s residence; Rachel was crying and screaming over the phone.
Berriel met Luis in the street; Rachel was at least fifteen feet away and not involved in the confrontation.
Berriel thrust a knife toward Luis; Luis defended himself and was injured; Berriel fled the scene.
The district court gave a self-defense instruction but refused to instruct on defense of a third person; court of appeals affirmed; Utah Supreme Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by not instructing defense of a third person	Berriel asserts evidence supports defense of Rachel.	Berriel contends no evidence supports third-person defense.	No reversible error; insufficient evidence for third-person defense.
Whether there was any basis in the evidence for a defense-of-a-third-person instruction	Evidence showed Rachel was in imminent danger requiring defense.	Danger to Rachel was not imminent when stabbing occurred.	Not supported; no imminent danger or necessity shown.
What is the proper standard of review for jury-instruction rulings in this context	Review under a correctness standard supports reversal if instruction justified.	Standard is abuse of discretion; district court did not err under either standard.	Abuse-of-discretion review applies; result aligns with either standard here.

State v. Brown, 607 P.2d 261 (Utah 1980) (entitled to jury instruction if supported by evidence)
Miller v. Utah Dep’t of Transp., 2012 UT 54 (Utah 2012) (abuse-of-discretion standard for jury instructions)
State v. Hernandez, 861 P.2d 814 (Kan. 1993) (history of abuse not by itself creates imminent danger)