My post yesterday about the Federal lawsuit brought by one Kayla Giles against USCCA resulted in a fair-sized tsunami of feedback, both positive and negative. In that lawsuit, Giles claims that USCCA is failing to meet their “self-defense insurance” obligations towards her as a Platinum member.
By the way, if you missed that LIVE post yesterday, you can find the replay, as well as the full-text version, on our blog here.
All that feedback, both positive and negative, is great because it gives me the opportunity to talk and write more about self-defense law, and all of you who know me know that I like to talk and write about self-defense law a great deal. So that’s what I’ll do in today’s show.
In particular, in today’s LIVE show we talk about how a claim of self-defense is evaluated on its merits. That is, some claims of self-defense are at least arguably of merit, while others are patently ridiculous, and the two claims ought not to be treated the same. So, what mechanism do we use to differentiate between claims of self-defense that have enough merit to be hashed out in court, and those that ought never make it into court in the first place?
OK, let’s dive into the substance of today’s show.
Kayla Giles shot and killed her estranged husband in a Walmart parking lot during a custody swap of their children. She has been charged with second-degree murder, and has raised the legal defense of self-defense. She is suing USCCA on the grounds that they have failed to meet their obligations to her, as a Platinum member of the organization, to pay her legal defenses in this self-defense case.
Perhaps the most common category of feedback I’ve received on this matter has to do with the particular alleged facts of the Giles case, in particular the circumstantial evidence surrounding the shooting of her husband. Much of that circumstantial evidence is arguably inconsistent with self-defense. In light of that evidence, might it not be appropriate for USCCA to decline to cover Giles legal expenses?
Here’s an example of what I mean, left as an comment to yesterday’s post (linked above):
I know I should distrust media, and I was not there in the Walmart parking lot when Giles shot her estranged husband. I don’t know all the contractual language in the USCCA insurance, but let me be the devil’s advocate. The deceased filed for sole custody claiming Giles was abusive. Media claims there were three instances where Giles was the aggressor against the deceased. So 12 days before the shooting, she buys a handgun and make the first payment for the platinum self defense insurance. Maybe the Walmart video will reveal the contrary, but on the surface it sounds fishy. Doesn’t some evidence have to be present to be able to argue self defense at trial, not just a empty claim? Otherwise it looks like a simple murder conviction. I must be missing something. So if you want to take someone’s life, you buy a gun, insurance, shoot, claim self defense, and get half a million dollars to play with? The more money, the more justice you can buy?
—Guilty as Charged (commenter chose to remain anonymous)
That’s a really excellent series of question, so I’m particularly pleased that it was addressed to Law of Self Defense, where I can provide a really excellent series of answers.
First, let me start at the end and address this question: “The more money, the more justice you can buy?” I’m going to sidestep the term “justice,” as I expect different people will have different definitions of what they consider “justice,” and instead suggest that the relevant term is “resources.”
And, yes, absolutely, the more money you can bring to the legal fight, means the more resources you can bring to that fight—including lawyers, experts, consultants, support staff, independent forensics, aggressive jury selection, and much, much more—and the more resources you can bring to the fight the better your chances of winning that fight, all other factors being equal. Just like in any other battle.
We might wish we lived in a world in which resources were not a factor in winning, but that’s not the world we live in. Importantly, the prosecution has essentially unlimited resources they can bring to the legal battle, for all practical purposes from the view of the defendant. Is it “justice” if the defendant is limited to only whatever resources they happen to have in their pockets when they’re arrested? Is it “justice” if the defendant is limited to only whatever resources are in their bank account on that particular day? What they can borrow from friends or family?
Or does it look more like “justice” if the state and the defendant have something resembling comparable resources to bring to the fight? If the defendant has a “self-defense insurance” provider backing their legal defense costs with resources must greater than the defendant is likely to have themselves?
I’d argue that this rough comparability is where we want to be, as general public policy with an interest in “justice”—and most especially if we’re actually the defendant.
Second, let’s keep in mind that the factual claims stated are just that, claims. They have not been subject to any adversarial process, nor assessed for credibility by a jury. The victim in this case claimed in divorce proceedings that Giles was abusive.
Does that mean the claim is true? I’m sure we’re all aware that false claims are made in courts all the time, and particularly in emotionally-laden proceedings like a divorce. Also, what’s “abusive” mean in this context? Physically abusive? Emotionally abusive? Denied sexual relations abusive?
It’s also not unusual for abuse in a relationship to go both ways. Perhaps even if it’s true that Giles was abusive to the victim, maybe it’s also true that the victim was abusive to Giles. Until we hear the arguments from both sides, can we know?
Further, regardless of whatever prior abuse might have existed, is it impossible that the victim here presented, in that moment in the Walmart parking lot, an imminent deadly force threat to Giles? Literally impossible? Was the victim immune from emotion, especially the emotions of a parent of children in a custody battle during a divorce? Was the victim incapable of causing harm to another? Of course not.
Bottom line, until the contesting narratives are each made in full, preferably in an adversarial process in which each narrative is challenged, we don’t have any realistic way of assessing the relative credibility of either narrative.
Certainly, we’ve learned from media coverage of such cases as the George Zimmerman trial, the Baltimore “Freddie Gray” trials, and the Ferguson “Hands-up, Don’t shoot” hoax that relying on whatever the media chooses to report about any use-of-force event is fraught with peril.
Now, let’s consider self-defense claims generally, in terms of differentiating between claims of self-defense that are at least somewhat credible as opposed to those that are not credible at all, or even worse claims that are completely ridiculous. After we ought to have a mechanism for differentiating between completely ridiculous claims of self-defense and arguably credible claims of self-defense, right?
Right. And therefore it’s a good thing that the criminal justice system actually has precisely such a system already in place.
OK, now let’s dive into how the criminal justice system distinguishes between completely ridiculous claims of self-defense, which ought to be discarded from serious consideration early and often, from more credible claims of self-defense, where a defendant ought to be entitled to present their argument to a jury.
It may be useful to think of self-defense claims as falling into one of three “buckets” along a continuum, with two very small “buckets” on each end, and one very large “bucket” in the middle.
On the extreme right side of the continuum we have “air-tight self-defense” cases. This might be where you’re awakened during the night while sleeping in bed at home, you go take a look to see what’s going on, only to find a machete-wielding stranger rushing at you across your living room. You shoot that attacking stranger in the chest, and he falls at your feet, machete still gripped in his hand.
There’s literally no interpretation of those facts that is inconsistent with self-defense. This, in a legal environment in which a prosecutor is obliged not merely to disprove self-defense, but to disprove self-defense beyond any reasonable doubt. On these facts, no reasonable jury could ever conclude that self-defense has been disproven beyond a reasonable doubt.
These “air-tight cases of self-defense” don’t then to progress through the criminal justice pipeline for the obvious reason that they’re simply impossible for the state to win, and are therefore never pursued for prosecution.
On the extreme left side of the continuum we have the “clearly not self-defense” cases. These are cases in which there is literally evidence in support of any one of the required elements of a self-defense claim. Imagine the same scenario just described, except the machete-wielding attacker wins the fight, is arrested, and charged. There is no interpretation of the facts described that would support a claim of self-defense by a machete-wielding man who breaks into a stranger’s home in the middle of the night and attacks the homeowner in his living room.
This bucket of purported cases of self-defense are actually the most common form of self-defense claims. The simple truth is that most cases of self-defense in the criminal justice system are simply nonsense claims, made by bad guys who have unlawfully used force against another person, and are now desperately seeking to escape righteous criminal liability for their unlawful use of force.
So, what happens when a nonsense claim of self-defense is made by a defendant? Does it automatically make it all the way to a jury, no matter what?
No, it does not. And here’s where it’s important to understand the burdens of proof. That’s not a typo, I mean that to be plural, burdens of proof with an s. Because there’s not just one burden of proof, there are two: the burden of production, and the burden of persuasion.
Let’s tackle the burden of production first.
Before any legal argument can be made to a jury, before it can actually get into the courtroom, the person proposing that legal argument first has to meet what’s called their “burden of production” on that legal argument.
We’ve all heard of cases in which some evidence was excluded from a trial. Perhaps the warrant used to collect that evidence was defective in some way. Perhaps the judge decided that the evidence was too prejudicial. Whatever the reason, the evidence was excluded. Well, if the evidence is excluded, the jury never sees it. If the jury never sees it, it can’t play a role in the jury’s decision-making in arriving at a verdict.
Exactly the same principle applies to legal arguments. Your attorney is not allowed to make in court any legal argument that pops into his head. Any legal argument your lawyer wants to make has to have some evidentiary foundation—there must be some evidence in support of that argument.
If there’s literally zero evidence in support of a legal argument, that legal argument cannot be made to the jury. Why not? Well, think about what the jury’s role is—to evaluate the credibility of evidence and determine whether an argument has been proven to the required legal standard. If there’s literally zero evidence in support of a legal argument, then there’s nothing for the jury to consider, and from a strictly technical perspective the argument simply can’t be proven.
So, how does this play out in the criminal justice process, from a practical perspective?
If a defendant has been charged with some use-of-force offense (assault, battery, manslaughter, murder, etc.) and wishes to justify their use of force as lawful self-defense, they typically are required to provide notice to the court—and, more relevant, to the prosecution—that they intend to argue self-defense as their legal defense.
This gives the prosecution the opportunity to challenge the right of the defense to argue self-defense, by arguing that the defense has failed to meet their burden of production on the legal argument of self-defense. That is, the state can argue that the defendant has failed to produce any evidence in support of self-defense (meaning, of course, each of the required elements of a claim of self-defense).
If it’s true that there is zero evidence in support of a required element of self-defense, then there’s no evidence for the jury to consider, and therefore there’s no way a rational jury could ever conclude the defendant acted in self-defense.
This is where nonsense claims of self-defense get blown up—before the trial even begins. The defendant proposes to raise the legal defense of self-defense, the prosecution demands that they show greater than zero evidence in support of each of the required elements of self-defense, the defense is unable to meet this requirement, and the trial judge denies the defense the right to argue self-defense in front of the jury.
Let’s put all that in the context of Gayla Kiles shooting and killing her husband.
It’s not hard to imagine a hypothetical fact pattern in which Kiles might have shot and killed her estranged husband and there would be zero evidence in support of self-defense. Say, for example, she’d broken into his home in the middle of the night, bringing a gun with her, snuck into his bedroom, and shot him in the back of the head as he slept.
There’s literally no interpretation of those facts that could support a claim by Kiles, in that hypothetical, that she shot her husband in self-defense. Under those hypothetical circumstances, if Kiles tried to claim self-defense the prosecution would demand that she first meet her burden of production on that defense. When she failed to do so, the trial judge would deny her the right to argue self-defense as a legal defense to the jury.
That, folks, is how a nonsense claim of self-defense gets rejected outright by the criminal justice system.
The reality of Kiles shooting and killing her estranged husband is not, however, that clear-cut. It is, rather, far more ambiguous. And that gets us to the really broad bucket in the middle of the continuum, what I refer to as the “bucket of ambiguity.”
Now we’re neither on the right end of the continuum, where the use of force was obviously self-defense, and we’re not on the left end of the continuum, where the use of force was obviously not self-defense. We’re in the middle, where the simple truth is that it could go either way.
In a moment I’ll focus us back in on the key question to be answered in this analysis, which is whether Giles has met the legal threshold for her shooting of her husband to qualify as a self-defense case for which USCCA might be obliged to compensate her legal expenses.
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OK, now let’s refocus on the key question to be answered in this analysis, particularly in the context of whether Giles has met her burden of production on self-defense, and thus met the threshold for this being considered a legitimate self-defense case regardless of the circumstantial evidence to the contrary.
The relevant question here, at this stage of the legal proceedings, is not whether we think it’s more likely than not that Kiles killed her husband in self-defense, on the one hand, or maliciously orchestrated a situation in which she could kill her husband and try to make it appear as self-defense.
That will most definitely be the key question at trial, where each of those narratives will be argued by the defense and the prosecution, respectively, and ultimate the jury will have to make the call.
It is not, however, the question to be answered pre-trial. The only relevant question to be answered in this context pre-trial is this: Is there more than zero evidence in support of Kiles claim of self-defense? To put it another way, is there any interpretation of the facts that could be consistent with Kiles shooting of her husband being self-defense?
The answer is obviously, yes. You may believe that it’s unlikely that Kiles shooting of her husband was self-defense. But no reasonable person could say it’s impossible, even accepting the worst interpretation of the known facts against her.
It could be true that Kiles had a reasonable perception of a deadly force threat from her estranged husband, even if she had only recently purchased her handgun, and even if she had only recently become a USCCA member, and even if her husband had previously accused her of domestic violence.
All of that could be true—and Kiles estranged husband could still have attempted to force his way into her vehicle, creating a legal presumption that he intended to cause her (and the children in the vehicle with her) deadly force harm.
Now, you may believe that this narrative is not credible, indeed you may believe it’s laughable.
But once there is more than zero evidence in support of that claim of self-defense, it’s no longer up to you, or me, or the prosecution, or even the trial judge, to deny the defendant the right to make that legal argument of self-defense in front of a jury.
Once there is evidence in support of a legal argument, it is the sole province of the jury to determine whether they consider that evidence to be credible or not credible, and by extension to determine whether self-defense has been disproven beyond a reasonable doubt by the prosecution.
And that is what we call the burden of persuasion, the second of the burdens of proof. That is, whose job is it to persuade the jury of the truth or untruth of that evidence or legal argument that’s met its burden of production and has now been presented to jury in court?
With respect to the legal defense of self-defense, once a defendant has met their burden of production on self-defense, and gotten the self-defense argument into court in the first place, the burden of persuading the jury that the claim of self-defense is untrue now shifts to the prosecution.
In this particular case, once Kiles has met her burden of production, and there’s any possible interpretation of the facts that could be consistent with self-defense, the burden of persuasion now shifts to the prosecution to disprove her claim of self-defense beyond a reasonable doubt.
Once Kiles has met her burden of production she is not obliged to also prove that she definitely killed her husband in self-defense. She’s not even obliged to prove that she probably killed her husband in self-defense. She’s not even obliged to prove she likely killed her husband in self-defense. All she’s obliged to do is ensure that the jury has a reasonable doubt about whether she killed her husband in self-defense.
Unless the state can disprove self-defense beyond that reasonable doubt, the jury will be instructed that they are to acquit Giles of second-degree murder and all lesser-included use-of-force charges that may apply.
So, let’s review in a nutshell, in the context of Kiles shooting of her husband, and in the context of USCCA’s obligation to compensate her for her legal defenses:
If there’s no interpretation of the facts that is consistent with self-defense, then Giles fails to meet her burden of production on self-defense, and self-defense is denied as a legal defense even before Kiles gets to trial. In that event, it would be perfectly reasonable for USCCA to decline to pay for Kiles’ legal expenses, because as a strictly technical legal matter her shooting of her husband could not have been self-defense.
On the other hand, if there’s ANY interpretation of the facts that is consistent with self-defense, then Kiles has met her burden of production on self-defense, self-defense is permitted as a legal defense, and will be argued to the jury. This is true even if any of us might feel that the evidence in support of self-defense is weak or strongly contested. If the evidence exists, it becomes the sole role of the jury to determine the credibility of that evidence, and by extension to determine if the legal defense of self-defense has been disproven by the prosecution beyond a reasonable doubt.
Again, once the burden of production has been met, self-defense is a viable legal defense in the criminal proceeding, and the only entity that gets to reject self-defense as a legal defense is the jury. Not the prosecution. Not the judge. Not USCCA. Not you. Not me.
Only. The. Jury.
From my perspective, the ideal “self-defense insurance” program would follow this framework precisely. Specifically, if a member fails to meet their burden of production on self-defense, the provider is relieved of their obligation to pay for the member’s legal expenses. On the other hand, if the member meets their burden of production on self-defense, meaning self-defense is now a viable legal defense in their trial, then the provider should be bound to meet their obligation to pay for the member’s legal expenses.
There is, of course, no ideal “self-defense insurance” program, as all of them have strengths and weaknesses. Indeed, all of them are free to require additional conditions and exxclusions for coverage beyond what I’ve described above, as part of their contractual agreement with their members, and to a greater or lesser extent they mostly do.
A “self-defense insurance” provider could do all I described, but also impose an exclusion that they are not obliged to cover cases in which the member was intoxicated at the time they acted in self-defense.
Totally legitimate, assuming the member knows that’s an exclusion going into the deal.
Alternatively, the provider could impose a condition that their coverage applies only if the member uses a firearm as their defensive tool, rather than a knife or a club or a car or an anvil or whatever, making the program gun-specific.
Again, totally legitimate, assuming the member knows that’s a condition going into the deal.
The provider could even impose an exclusion such that their benefits are not triggered if the use-of-force was the result of a domestic relations confrontation. This particular exclusion would, for example, relieve a “self-defense insurance” provider from covering Kiles under the facts of this case.
Again, totally legitimate. Assuming the member knows that’s an exclusion going into the deal.
What one needs to be cautious about in considering any “self-defense insurance” program is not whether they will be denied benefits if their use-of-force could not have been self-defense from a technical legal perspective—that goes without saying.
Nor should one be concerned that they might be denied benefits if their use-of-force fails to meet one of the conditions, or triggers one of the exclusions, of the program they chose. That’s on the member—if you don’t agree with the conditions or exclusions of a given program, don’t sign up for that program—it’s a poor fit for you. Once you sign up, however, you’re as bound by those conditions and exclusions as the program is by their obligations to you should you be in compliance with those conditions and exclusions.
Where anybody enrolled in or considering a “self-defense insurance” program SHOULD be concerned is where such a provider decides, without prior notice to the member, that they will condition providing benefits on their own determination of whether they find the member’s claim of self-defense to be credible.
In other words, that the provider will give the member the promised benefits, but only if it looks like self-defense to provider.
I want to make clear that such a condition of discretionary review would be totally appropriate for any “self-defense insurance” provider, so long as prospective members were made aware of this condition going into the deal.
There’s no reason that a provider can’t impose as a condition of benefits that they are entitled to review the member’s use-of-force and make their own determination of whether, in their judgment and completely independent of what any court might find, that use-of-force qualifies as self-defense. In this case they would reserve the option to deny benefits at their discretion should they conclude, in their judgment, that the use of force does not look like self-defense to them.
Under this model, the “self-defense insurance” provider is in effect assuming the role of the judge in deciding whether the member has met their burden of production, and the role of the jury in deciding whether the state has met its burden of persuasion.
Again, totally legitimate. Assuming the member knows that’s an exclusion going into the deal.
Now, this kind of “we’ll cover you if we feel like it” program is not something I’d feel particularly comfortable recommending to clients and members of the Law of Self Defense community, because of the lack of certainty involved. What are you really paying for every month, if when you need to access those “self-defense insurance” benefits your provider can deny you at their own discretion, even if a court says your claim of self-defense is viable?
A strong argument can be made that such discretionary authority on the part of a “self-defense insurance” provider might be acceptable if the provider has an exceptional capability of making such judgments in a credible way.
Many would argue, for example, that the Armed Citizen Legal Defense Network has precisely such a capability in their truly exceptional Board (consisting of folks like Mas Ayoob, John Farnam, Tom Givens, Dennis Tueller, etc.). Nevertheless, whether a provider reserves the right to deny benefits at their sole discretion, even if a court finds a claim of self-defense to be viable for trial, is a factor that ought to be given considerable weight in choosing a “self-defense insurance” provider.
To come back to the case of Kayla Giles, if a court concludes that she has failed to meet her burden of production on self-defense—in effect, the there is no view of the facts that could be interpreted as consistent with self-defense—then USCCA ought not be obliged to pay for her legal defense, no matter what other factors might be in play.
If Giles meets her burden of production, but has failed to meet some previously disclosed condition, or has triggered some previously disclosed exclusion, of her membership agreement with USCCA, then USCCA ought not be obliged to pay for her legal defense, no matter what other factors might be in play.
If, however, Giles meets her burden of production, by convincing the trial court that her claim of self-defense is sufficiently viable to be argued before the jury, and she has met all previously disclosed conditions and has not triggered any previously disclosed exceptions to her membership agreement with USCCA, then it would appear that USCCA ought to be obliged to pay for her legal defense—again, no matter what other factors might be in play.
And that obligation ought to apply even it appears likely that Giles may have orchestrated the murder of her husband and attempted to fake the appearance of self-defense. Why?
Because if she’s met her burden of production, has met the conditions of her membership agreement, has not triggered any exclusions of that agreement, she is entitled to have the jury, and not USCCA, make the determination of whether the state has disproven her claim of self-defense beyond a reasonable doubt.
And all that’s true even if it later turns out that the jury convicts Giles of second-degree murder in the killing of her husband. The whole point of “self-defense insurance” is to provide members with resources to wage their legal fight in the first place. By definition, that means the resources have to be provided before the verdict is in, and therefore before the final outcome can be known. If the promised resources are withheld until after the verdict, and provided only if the verdict is not guilty, such that the defendant lacked those resources for the fight, and that lack of resources might well have directly contributed to the defendant’s conviction. (That’s why I’ve never recommended “self-defense insurance” programs that are largely or entirely reimbursement-after-the-verdict programs, such as the now-defunct NRA Carry Guard program.)
Does all this mean that in some cases a “self-defense insurance” program will find itself obliged to pay the legal defenses of a member who the program genuinely, and in good faith, believes orchestrated the victim’s murder?
Yes. If they don’t want to be in that position, all they need to do is inform prospective members ahead of time that they reserve the option to deny benefits at their sole discretion.
Whether such a program would prove a viable business model is another matter entirely.
Law of Self Defense CONSULT Program
And with that, it seems this might be a good idea to mention a rapidly closing opportunity with respect to our Law of Self Defense CONSULT Program.
For those who don’t know, our CONSULT Program is a way for you to guarantee that I’ll be available to work on your self-defense case should you ever find yourself facing a use-of-force criminal charge, and at a small fraction of my normal retainer cost.
Note that the CONSULT Program is NOT a replacement for a “self-defense insurance” program. The CONSULT Program does NOT cover the entirety of your legal expenses. It’s simply a way to pre-pay, at a fraction of the cost, the cost of my consulting on your case, and at roughly 1/10th the cost of our usual retainer.
Perhaps the biggest strength of the CONSULT Program, however, touches upon many of the arguable weaknesses we’ve just discussed in the context of most of the “self-defense insurance” programs, and that is that we impose no circumstantial exclusions on participation in the CONSULT Program.
Had you consumed a few beers when you acted in self-defense? If so, many “self-defense insurance” providers reserve the right to decline coverage. The CONSULT Program doesn’t care, you get our services anyway.
Was the use-of-force event the result of a violent domestic relationship? If so, some “self-defense insurance” providers reserve the right to decline coverage. The CONSULT Program doesn’t care, you get our services anyway.
Do you live in one of the increasing number of states that have effectively outlawed “self-defense insurance” providers? As a traditional pre-paid legal services program, without any insurance component whatever, the CONSULT Program isn’t subject to such restrictions, so you get our services anyway.
In other words, even if for some reason your self-defense insurance” provider becomes unwilling or unable to help you in your time of legal distress, the CONSULT Program generally, and I personally, will still be there.
Here’s the important point I wanted to bring to your attention with respect to this week in particular:
On November 1, the cost of joining the CONSULT Program via a single up-front payment goes up rather substantially, effectively almost doubling. So, if you were interested in joining on that basis, you’ll absolutely want to take a look at that option within the next few days. After October 31, that option gets a lot more costly than is currently the case.
Alternatively, we’ve just launched an option to enroll in our CONSULT Program by making modest ongoing payments of less than $20 a month, rather than having to come up with several hundred dollars up-front. Best of all, you’re fully covered by the $10,000 of legal services offered under the CONSULT Program the moment we receive your first monthly investment of less than $20, and you continue to be covered as long as you choose to stay enrolled.
This monthly payment option is a bit of an experiment for us, however, and I’m not sure how long we’re going to offer it. We have no intention of dropping anyone from the program who signs up, but we reserve the right to cease offering this monthly option at our discretion. So, if you want to lock this opportunity in, now would be the time to do so.
To learn more about the Law of Self Defense CONSULT Program, just point your browser to:
OK, folks, that’s about it for today, I think.
Please remember: We don’t yet know all the facts regarding this lawsuit brought by Kayla Giles against USCCA (meaning, parent company Delta Defense), and it’s possible that USCCA has a perfectly valid explanation that completely counters Giles’ claims.
If so, however, USCCA has explicitly declined to provide that explanation—their media spokesperson provided me with a firm “No Comment” when I inquired. As is, of course, their privilege.
Absent an explanation countering credible allegations that they are improperly declining to meet their contractual obligations to one of their Platinum members charged with second-degree murder, however, I’m obliged to cease recommending to my clients and the Law of Self Defense community generally that USCCA be considered as a viable choice for “self-defense insurance.”
OK, folks, have a great weekend, and don’t forget:
In closing, remember:
You carry a gun so you’re hard to kill.
Know the law so you’re hard to convict.
Attorney Andrew F. Branca
Law of Self Defense LLC