State v. Norman, 324 N.C. 253, 378 S.E.2d 8 (1989)
State v. Norman is a seminal North Carolina Supreme Court decision that defines the outer limits of self-defense when invoked by battered spouses.
Whether evidence of prolonged and severe domestic abuse and battered spouse syndrome can support jury instructions on perfect or imperfect self-defense when the defendant killed her abuser while he was asleep, such that no imminent threat existed at the moment of the killing.
In North Carolina, perfect self-defense justifies a homicide when: (1) the defendant was not at fault in provoking or engaging in the confrontation; (2) the defendant actually believed it was necessary to kill to save herself from death or great bodily harm; (3) the belief was reasonable under the circumstances; and (4) the threatened harm was imminent. Imperfect self-defense mitigates murder to voluntary manslaughter when the defendant, though not entitled to perfect self-defense (for example, because her belief was unreasonable), nevertheless actually believed it was necessary to kill to protect herself from imminent death or great bodily harm. The requirement of imminence is not satisfied by threats of future harm or by general ongoing danger; it requires an immediate threat at the time deadly force is used. Expert testimony on battered spouse syndrome may be relevant to the reasonableness and subjective perception of danger, but it does not eliminate the legal requirement of imminence.
No. Because the deceased was asleep and posed no immediate threat at the moment of the killing, the evidence did not support submission of either perfect or imperfect self-defense to the jury. The Court reversed the Court of Appeals and reinstated the voluntary manslaughter conviction.
Norman is a leading case on the limits of self-defense for battered spouses. It teaches that expert evidence of battering informs the reasonableness of a defendant's perception but cannot replace the legal requirement that the threat be imminent at the moment of the killing. For law students, the case is essential to understanding the difference between justification (self-defense) and mitigation (imperfect self-defense), the function of the imminence element as a limiting principle, and how social science evidence interacts with established doctrinal elements. Norman also frames ongoing debates about whether legislative reforms or alternative defenses should address situations where long-term abuse creates a credible but non-immediate risk of lethal harm.