The SDA does not define “force” or “deadly force.” Our Supreme Court, however, has
applied the term “deadly force” as defined as force used in a circumstance in which the natural,
probable, and foreseeable consequence of the act is death. People v Couch, 436 Mich 414, 428 n
3; 461 NW2d 683 (1990). In People v Pace, 102 Mich App 522, 534; 302 NW2d 216 (1980),
this Court determined that a defendant’s mere display of a knife during a fight, while implying a
threat of violence, does not constitute deadly force. Id. at 533-534.
***
This holding, that a threat of deadly force is itself nondeadly force, is consistent with
Black’s Law Dictionary (11th ed), which defines nondeadly force as “1. Force that is neither
intended nor likely to cause death or serious bodily harm; force intended to cause only minor
bodily harm. 2. A threat of deadly force, such as displaying a knife.” Similarly, the treatise
LaFave & Scott, Criminal Law (2d ed), § 5.7, pp 455, states in relevant part, that “merely to
threaten death or serious bodily harm, without any intention to carry out the threat, is not to use
deadly force, so that one may be justified in pointing a gun at his attacker when he would not be
justified pulling the trigger.”
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