EDWARD BROWN v. UNITED STATES

EASTERLY, Associate Judge:

This court has long recognized the common-law defense that authorizes an individual to protect or repossess personal property using nondeadly force and that correspondingly prohibits the use of deadly force for this purpose. Deadly force is understood to include force likely to cause “serious bodily harm.” In this case, we consider whether the trial court should have, at Edward Brown’s request, defined “serious bodily harm” for the jury using the same definition this court adopted for “serious bodily injury” in the context of aggravated assault. See Nixon v. United…