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People v Goetz: Court Decision and Implications Case Study

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Updated: Jul 2nd, 2021

The court case of the appellant in the face of the People of the State of New York and the respondent in the face of Bernhard Goetz was argued and decided in the year 1986. This case provides a broad spectrum of thoughts about the perception of self-defense and its objectivity. Various scholars and researchers hold different views on this particular case, and many disputes about which decisions and actions can be considered reasonable were raised. The purpose of this paper is to study the People v Goetz case, analyze the court decision, and investigate its implications.

First, it is critical to look at the sequence of events that led to the creation of the incident. In December 1984, four males entered the subway train that headed to Manhattan. Later, Bernhard Goetz sat at the same train car close to the four youths mentioned above. Two of them approached Goetz and asked for five dollars. It turned out that Goetz had an unlicensed gun with him. After that, Goetz took out the pistol and started shooting at those men.

The evidence showed that the first shot got into the chest of the first guys. The second shot got into the other’s back, and the third one went into the arm and the left side of the third male. The fourth shot was aimed at the last one from the group, but Goetz missed it (People v. Goetz, 1986). However, after observing the scene in the train, Goetz saw the fourth man sitting on the bench and fired at him, severely damaging the spinal cord.

At the same time, the conductor was at the neighboring train car and heard the gunshots, after which he immediately requested the emergency assistance. As soon as the conductor came into the cabin, he saw the injured guys, Goetz, and a couple of passengers lying on the floor. Bernhard Goetz claimed to the conductor that those youths took an effort to rob him. After that, Goetz headed to the front of the cabin, jumped on the tracks, and escaped. Nine days later, Bernhard Goetz surrendered to the police as the suspect in the subway shooting in New York on December 22 (People v. Goetz, 1986). The paragraphs above provide a brief description of the incident, which led to the court trial and has references and implications in other cases until nowadays.

It was crucial to know the events in the subway on that day to analyze the court’s decision and its justice. The Grand Jury indicted Goetz “on attempted murder, assault, and other charges for having shot and wounded for youths on a New York City subway” (People v. Goetz, 1986).

Nevertheless, the lower courts dismissed those indictments and charged Bernhard Goetz only with the illegal possession of the gun. This case and its outcomes illustrate the importance of the perception of reasonability. The primary claim in defense of Goetz was that his actions represented the self-defense of a reasonable person who was afraid that the offenders would hurt him. Although there was no evidence that any of the four wounded men showed or possessed any weapon during that event, Goetz’s actions were justified by that defense (People v. Goetz, 1986). Thus, Goetz’s fear was caused by the actions of the four men.

It is integral to raise a point about the criminal situation in New York at the time the incident took place. When it happened, the rates of violent crimes in New York were very high, which strengthened the fear in people, instilling a need to have something to protect oneself. It also implies that there were many victims of robberies and attacks. Because of the city’s diversity, New York was considered to be full of hate crimes and inter-groups hassles (Levin & Amster, 2007).

Thus, those who were identified to be the victims received great support. The organization called the Guardian Angels existed in America at that moment, and it was entirely on the side of Bernhard Goetz. This organization worked hard to raise money for Goetz’s defense. Even the Congress of Racial Equality defended the respondent in public (Chapman & Ciment, 2014). The situation in the country at that period had an impact on the whole trial process for the case People v. Goetz.

The decisions that a person makes under different circumstances can be explained by various factors, such as victimization or prior offense history. Goetz’s family had a history of abuse, where his father was accused of abusing two boys, and Bernhard was mugged twice before. The researchers suggest that Goetz always had trouble interacting with people, but he realized that he could not escape that for work and social life. During the mugging incident that happened to Bernhard, the police did not arrive immediately, and then released the offenders later only after a few hours of interrogations.

That event left serious physical marks on Goetz and strengthened his distrust of the criminal justice and the belief in the necessity of self-defense (Robinson et al., 2016). However, those biographical notes imply that Goetz was more of a loner and that the echoes of previous offenses were haunting him.

Many scholars differ in their views on the standard of a reasonable person in criminal justice. For example, Cynthia Lee suggests that due to the reasonableness requirement, “a completely irrational actor cannot get away with murder” (Lee, 2005). Acevedo (2014), in turn, states that there are three bases used to understand this standard. First, he claims that this principle is too abstract and general, and it cannot reflect the intentions of the person within a specific situation. Second, he states that the definition of self-defense of a reasonable man is far from being objective because it depends on the individual’s perception of the circumstances.

Finally, the third basis that Acevedo mentions is the fact that a reasonable man standard spread the prevailing culture and neglects the minority groups (Acevedo, 2014). Moreover, Carlson (2016) proposes that the principles of moral panic lead to certain self-defense actions, which is also a subjective measure. Consequently, the process of judging individuals’ actions is challenging and imposes many controversies.

People v. Goetz’s case founded a ground for many racial disputes. The four youths, whom Goetz shot in the subway in 1984, were Afro-Americans. According to Fluehr-Lobban (2018), this particular shooting case became an example of reasonable racism. The author suggests that critical race theorists believe that a white person can justify his actions against a representative of another race under the circumstances of reasonable fear (Fluehr-Lobban, 2018).

Another scholar argues that the race factor “dictated which passengers were understood to be innocent and which were presumed guilty” (Mann, 2017, p.66). When Goetz was describing his version of the events, he called the man whom he shot “the blacks.” It points out that he did not use the neutral descriptions and raised many questions concerning his real intentions (Mann, 2017). Thus, the issue of race also played an essential role in the perception of this court case and its decision, raising questions and linking it to new cases until today.

This case seriously implies the importance of the definition of self-defense, its rationale, and its necessity. The book Killing in Self-Defense argues that self-defense is, in fact, the most reliable way of defending a respondent among all the criminal cases.

There are numerous occasions in which self-defense might be the only option to protect oneself and survive. However, the emphasis on everyone’s right to life should not be neglected when the conversation is about shooting as a measure of self-defense. Thus, the necessity of using deadly force should be justified. It implies that a person should think carefully before using a defensive force and should understand the accuracy of his thoughts before making a move (Leverick, 2006). Hence, criminal justice must assess the level of self-defense need objectively.

People v. Goetz’s case raises many problems that continuously emerge in the criminal justice world. Among those, there are the issues of a reasonable man definition, the definition and the necessity of self-defense, racial discrimination within the criminal justice system, and reasonable racism. There are diverse views on those aspects, but in terms of Goetz’s case, there are controversies up till today. It is possible to state that this specific trial represents the value of objectivity within criminal justice.


Acevedo, J. P. P. L. (2014). The inconvenience of the reasonable person standard in criminal law. Derecho PUCP, (73), 505-509.

Carlson, J. (2016). Moral panic, moral breach: Bernhard Goetz, George Zimmerman, and racialized news reporting in contested cases of self-defense. Social Problems, 63(1), 1-20.

Chapman, R. M., & Ciment, J. R. (Eds.). (2014). Culture wars in America an encyclopedia of issues, viewpoints, and voices (2nd ed., Vol. 1-3). Routledge.

Fluehr-Lobban, C. (2018). Race and racism: An introduction (2nd ed.). Rowman & Littlefield.

Lee, C. (2005). Murder and the reasonable man revisited: A Response to Victoria Nourse. Ohio State Journal of Criminal Law, 3(1), 301-306.

Leverick, F. (2006). Killing in self-defence. Oxford University Press.

Levin, B., & Amster, S. E. (2007). Making hate history: Hate crime and policing in America’s most diverse city. American Behavioral Scientist, 51(2), 319-348.

Mann, J. L. (2017). The “Vigilante spirit”: Surveillance and racial violence in 1980s New York. Surveillance & Society, 15(1), 56-67.

People v. Goetz, 68 NY2d 96, (1986).

Robinson, P. H., Baughman, S. B., & Cahill, M. T. (2016). Criminal law: Case studies and controversies. Wolters Kluwer Law & Business.

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