The state Court of Appeals ruled that Ronald Wayne Vaughn Jr., who was convicted of killing his landlord’s son with a sawed-off shotgun, is entitled to a new trial because the presiding judge failed to instruct jurors about a possible self-defense argument. The incident occurred when Vaughn was on the porch of the Lincoln County trailer he was renting and had the weapon, and the victim rushed at him after a heated argument. The first-degree murder conviction of Vaughn was vacated, and he was sentenced to life in prison without parole. Vaughn was also convicted of possessing a felony gun.
Although possessing a gun like the one Vaughn used is a felony, the state’s “stand-your-ground” law allows a person to use force to prevent imminent death or great bodily harm without a duty to retreat. However, this defense cannot be used when the person was committing a felony at the time. A state Supreme Court ruling after Vaughn’s trial narrowed this exception, requiring a determination that the injury would not have occurred if the person did not possess the weapon. The Court of Appeals ruled that the jury should have been instructed on the stand-your-ground provision in Vaughn’s case.
The altercation leading to the shooting occurred after Vaughn was given notice to leave the trailer he was renting, which he ripped up. Vaughn tried to call 911 but was unsuccessful, and he told the victim and his mother from the porch that they needed to leave instead. The evidence could have supported a determination that Vaughn’s use of deadly force was justified, and there was no causal nexus between the disqualifying felony and his use of deadly force, according to Judge Allegra Collins. The prosecutor erroneously told the jurors that the stand-your-ground provision did not apply in the case.
The Court of Appeals found no error in Vaughn’s conviction for possessing a weapon of mass death and destruction, resulting in a prison sentence of almost 2 1/2 years. The judges ordered that Vaughn be resentenced considering his pre-trial confinement credits. The panel agreed that Vaughn should receive a new trial due to the failure to instruct the jurors on the stand-your-ground provision, which could have affected the outcome of the case. This ruling highlights the importance of ensuring that all relevant legal defenses are properly presented to the jury in criminal cases.
