United States v. Aaron Taylor

OPINION OF THE COURT

RENDELL, Circuit Judge.

This case requires us to consider whether, by including “without just cause or excuse” in the federal assault with a dangerous weapon statute, 18 U.S.C. § 113(a)(3), Congress intended to convert justification, ordinarily a common-law defense, into an element of the offense as to which the government bears the burden of proof beyond a reasonable doubt. Applying relevant Supreme Court precedent, we conclude that the existence of just cause or excuse is an affirmative defense to a § 113(a)(3) violation, and the defendant bears the burden of proving it…