United States v. Donzell Wayne Biggs, AKA Maynard Wayne Hurley

Donzell Wayne Biggs (aka Maynard Wayne Hurley) pleaded guilty to assault with a dangerous weapon in violation of 18 U.S.C. § 113 (a)(3) and possession of contraband in prison in violation of 18 U.S.C. § 1791 (a)(2). He was sentenced to 84 months in prison. The guilty plea reserved the right to argue on appeal that the district court erred by precluding Biggs from presenting evidence and arguing to a jury that he was acting in self-defense. Fed.R.Crim.P. 11(a)(2). We conclude that the district court failed to properly define the elements of a claim of self-defense.

I

Biggs has been in federal custody serving a life sentence for first degree murder since 1977. In 2001, Biggs was incarcerated at Lompoc, United States Penitentiary and was being housed in its administrative segregation unit. In the segregation unit, inmates are left in their two-person cells twenty-three hours a day. During the twenty-fourth hour, four prisoners at a time are allowed access to a recreation cage. Prisoners are walked handcuffed to the cage and, once inside, are instructed to put their hands through the bars so that officers can remove the handcuffs.

On April 26, 2001, Biggs attacked a fellow inmate,…