Dealing With the Wrongs and the Rights: Lessons on Lethal Self-Defense from Durham, North Carolina

Authors

• Emily Bass, Duke University School of Law

Abstract

The tragic loss of seventeen-year-old Trayvon Martin and the lack of accountability that George Zimmerman faced for fatally shooting him in their Florida neighborhood inspired countless calls for politicians to reexamine self-defense laws. Still, long before stand-your-ground laws, the same racist undertones that plagued Zimmerman’s trial prevented other state courts from holding accountable those who use excessive force in proclaimed “self-defense” and killed Black teenagers.

In 1993, then fifteen-year-old Jamal Elliott and several of his friends broke into the garage of Durham, North Carolina resident Michael Seagroves, hoping to steal a motorcycle. As Jamal ran from the garage, Seagroves shot him four times in the back. Jamal died just minutes later in a neighbor’s front yard. The incident divided their community for over a year after the jury deadlocked, the judge declared a mistrial, and the district attorney decided not to retry the case. But it was not enough that Seagroves evaded liability—instead, the incident inspired North Carolina lawmakers to fight for and subsequently pass the state’s first self-defense statute to protect future residents in Seagroves’s position.

Since then, North Carolina has taken significant steps to further protect private vigilantes who utilize lethal self-defense, including a new defense of habitation law and stand-your-ground statute. But a deeper look at North Carolina’s three decade-long history of statutory self-defense reflects the nation’s problematic tendency to disregard the disproportionate effects these laws have on Black victims.

Recommended Citation

Emily Bass, Dealing With the Wrongs and the Rights: Lessons on Lethal Self-Defense from Durham, North Carolina, 19 DePaul J. for Soc. Just. (2026)
Available at: https://via.library.depaul.edu/jsj/vol19/iss1/2