A successful defense of justifiable homicide requires that the defendant must have been in imminent life-threatening danger (as perceived by a reasonable person) and that the use of lethal force was the only reasonable means of surviving the threat of death or serious bodily harm. In this context, a significant court decision bearing upon the justifiable homicide defense by a battered woman was the Washington State Supreme Court's decision in State v. Wanrow (1977). The court reversed the trial court's conviction of the defendant because the jury instructions limited the defendant's perception of imminent danger to the immediate circumstances of the killing rather than including previous events that affected the defendant's perception of the victim's threat to her. This implies that a battered woman's killing of her batterer can be considered justifiable homicide based on previous beatings that gave the defendant reason to believe the victim was an imminent danger to her. Other factors favoring a justifiable homicide defense are the tendency of police and other community agencies not to intervene to protect battered women and the inability of women to use other than a lethal weapon to counter superior male physical power. 33 notes.