United States v. Biggs

441 F.3d 1069 (2006)

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Nature of the Case

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Facts

D is serving a life sentence for first-degree murder since 1977. D was incarcerated at Lompoc, United States Penitentiary and was being housed in its administrative segregation unit. D was in his two-person cell twenty-three hours a day. For an hour a day, four prisoners at a time are allowed access to a recreation cage. Prisoners are walked handcuffed to the cage and, once inside, are instructed to put their hands through the bars so that officers can remove the handcuffs. D attacked a fellow inmate, Michael Smith, with an 8-inch homemade knife while they were inside the recreation cage. Smith was stabbed in the arm and ear. At his trial D alleged that he was acting in self-defense because he knew that Smith had been attempting to procure a knife and had threatened him on the way to the cage. The court refused the defense of self-defense in that D could not show that there were no reasonable alternatives to the use of force.