When you’re carrying a firearm for self-defense—whether as a civilian with a CCW or a licensed armed guard—understanding the legal boundaries is everything. One of the most important Colorado self-defense cases ever decided is People v. La Voie, 395 P.2d 1001 (Colo. 1964). This case laid the foundation for what we now call the “reasonable belief” standard when it comes to using deadly force.
Here’s what happened, what the court said, and what this means for you as a responsible gun owner in Colorado.
🔹 What Happened in People v. La Voie?
Ronald La Voie was driving late at night when he was cut off by another car. He honked, and the other vehicle followed him into a parking lot. Four angry men got out and approached his car in what he described as an aggressive and threatening way. La Voie, fearing for his life, pulled a handgun and shot one of the men—killing him.
La Voie was charged with homicide, but the Colorado Supreme Court overturned the conviction and set a powerful legal precedent in doing so.
🔹 The Court’s Ruling: “Reasonable Belief” Justifies Action
The Colorado Supreme Court ruled that:
A person who is where they have a legal right to be, and who acts based on a reasonable belief that they are in imminent danger of death or serious bodily harm, is justified in using deadly force—even if that belief turns out to be mistaken.
This is a critical legal principle. The law doesn’t require you to be right, it requires you to be reasonable in what you believed at the time.
🔹 Why This Matters for Concealed Carriers and Armed Guards
- You don’t have to wait to be attacked: The law protects you before the punch or stab or shot happens—if the threat seems real and immediate.
- Your belief doesn’t have to be correct—just reasonable: That’s the standard. It’s what a jury will consider.
- Location matters: You must be someplace you have a legal right to be. In this case, La Voie was in a public parking lot.
🔹 A Real-World Application
Let’s say you’re working as an armed guard or you’re just a CCW holder walking to your car. Three people suddenly approach you aggressively, yelling threats and closing the distance fast. You draw your firearm and use deadly force because you believe you’re about to be attacked.
If that belief is considered reasonable under the circumstances—even if the attackers were bluffing—you could be justified under Colorado law, thanks to the precedent set in People v. La Voie.
🔹 Key Lessons for Armed Citizens and Professionals
- Know how to articulate your reasoning. After a use-of-force event, your ability to explain what you saw, heard, and felt will be critical.
- Don’t be the aggressor. You lose your legal protection if you start the fight.
- Stay calm, but decisive. Delayed reactions can cost lives—but so can rash ones. That’s why training matters.
- De-escalate when you can. Self-defense law protects necessary force—not avoidable violence.
🔚 Final Thoughts
People v. La Voie is a cornerstone case for Colorado self-defense law. It tells us that your judgment doesn’t have to be perfect—but it must be reasonable. In a high-stress encounter, that’s often the difference between being protected by the law or facing prosecution.
As always: get trained, know the law, and carry responsibly.
Need to understand Colorado’s new CCW laws?
Check out our latest blog on Colorado Revised Statute § 18-12-202.5 and how it affects your right to carry starting July 1st.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For legal guidance specific to your situation, please consult a qualified attorney licensed in Colorado.
