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Prior to 1970, the term "domestic violence" referred to ghetto riots and urban terrorism, not the abuse of women by their intimate partners. Today, of course, domestic violence is a household word. After all, it has now been ten years since the revelation of football star O.J. Simpson's history of battering purportedly sounded "a wake-up call for all of America"; ten years since Congress enacted legislation haled as "a milestone . . .truly a turning point in the national effort to break the cycle" of violence; and twenty years since Farrah Fawcett's portrayal of Francine Hughes in the movie The Burning Bed supposedly "left an indelible mark upon society's collective consciousness." Despite these and numerous other "milestones" and "wake-up calls," domestic violence continues to be a seemingly intractable problem in this country. Substantial numbers of women are still beaten by their husbands and boyfriends each day, and many of them die as a result. A much smaller number of women strike back and kill their abusers, but it is these cases - and the self-defense issues they raise - that seem to receive a disproportionate share of the attention.

The most troublesome self-defense questions arise, of course, in cases involving non-confrontational killings - where the woman struck back before or after a beating, or, most controversially, when her abuser was asleep. Although statistically most killings do not fall into this category, they raise the most difficult questions and have generated the most interest. Can a woman who kills under these circumstances legitimately argue that she acted in self-defense - that, pursuant to the prevailing definition of the defense, she honestly and reasonably believed she was in imminent danger of death or serious bodily harm? A number of critics contend that she cannot, and it is my purpose here to evaluate the arguments they have advanced.