The suspect in a 2025 self-defense trial should have been able to argue that his slain victim was a transgender woman and therefore a greater threat to his safety than jurors were told, the Tennessee Court of Criminal Appeals ruled Oct. 5
Samuel Ward was convicted of voluntary manslaughter for shooting Paris Lee six times in 2022. He claimed he fired in self-defense because Lee, who was Black, was born male and was armed. Ward at one time had a sexual relationship with the victim.
Prosecutors argued that the description of Lee as “a large woman” armed with a gun would be sufficient in Ward’s self-defense case and that introducing her gender at birth would introduce “a touchy subject” that could create bias among jurors, according to court documents.
Samuel Ward
The court sided with the state despite claims by Ward’s attorneys that the “relative strength of biological males” was essential in proving the defendant acted in self-defense.
But the appellate judges noted that “there are physical differences between a biological male who is 5-feet-11 and 262 pounds and a biological female who is 5-feet-11 and 262 pounds” that should have been included in Ward’s defense.
Prosecutors even “conceded that if the proof showed the victim’s assigned sex was the reason for the altercation between defendant and the victim, it would be relevant to the adequate provocation element of voluntary manslaughter,” the ruling added. The state also argued that Ward himself could face discrimination because he had been in a sexual relationship with a transgender woman.
“In this situation, however, evidence of the biological sex of the victim was relevant and full of probative value, and its exclusion left the jury with the impression that a male defendant killed a female victim,” the ruling concluded.
The decision overturned Ward’s conviction and ordered a new trial “because the trial court abused its discretion by excluding evidence of the victim’s biological sex.”
Some observers said the use of sexual and gender identity as a defense in criminal cases is common when LGBTQ victims are involved, the Advocate reported: “This approach to criminal defense gained notoriety after it was used by defendants in the brutal 1998 murder of gay college student Matthew Shepard by two men in Laramie, Wyo. Today, the LGBTQ panic defense is still not banned in Tennessee.”
Memphis-area LGBTQ organizers said Ward was a well-known threat to transgender women before fatally shooting Lee.
“What concerns me as a community organizer is what happens when a courtroom treats a Black trans woman’s identity as a material explanation for someone’s fears,” said Kayla Gore, executive director of My Sistah’s House in Memphis, in an interview with the blog Erin in the Morning. “They want that as evidence presented to the jury or the judge as a deciding factor on whether or not this was self-defense. It sends a message far beyond the courtroom.”