A Tennessee appeals court has overturned the manslaughter conviction of a man who fatally shot a Black transgender woman, ruling that jurors should have been allowed to hear evidence about the victim’s sex assigned at birth when considering the defendant’s claim of self-defense.
The October 5 decision by the Tennessee Court of Criminal Appeals has renewed concerns about the use of the controversial “trans panic” defense, a legal strategy in which defendants attempt to justify or minimize violence by invoking a victim’s transgender identity.
Samuel Ward Jr. was convicted of voluntary manslaughter in May 2025 for killing 36-year-old Paris Lee, also known as Kitty Monroe, outside her Memphis home in June 2022. According to prosecutors, Ward shot Lee six times before driving approximately 30 minutes to his home, leaving her to die.
Ward received a six-year prison sentence following his conviction.
Court Finds Transgender Identity Relevant to Defense
During the original trial, Ward maintained that he acted in self-defense, claiming Lee had threatened him with a firearm. His attorneys argued that jurors needed to know Lee was transgender to properly evaluate Ward’s perception of danger.
The trial judge prohibited references to Lee’s sex assigned at birth, determining that the information could prejudice jurors and distract from the circumstances surrounding her death.
However, the appellate court concluded that the exclusion was improper under Tennessee’s rules of evidence.
In its decision, the court stated, “We decline to hold that the biological sex of the victim is not relevant to a claim of self-defense.”
The judges also determined that the trial court had not adequately evaluated whether the potential prejudicial impact of the evidence outweighed its relevance.
The appellate ruling does not establish that Lee’s transgender identity justified her killing. Rather, it reverses Ward’s conviction and orders a new trial in which the disputed evidence may be considered.
Ruling Raises Concerns About Trans Panic Defenses
The decision has alarmed transgender advocates who argue that allowing a victim’s gender identity to influence assessments of danger risks reinforcing discriminatory stereotypes.
The LGBTQ+ panic defense is not a standalone criminal defense. Instead, it involves using a victim’s sexual orientation or gender identity to support arguments involving self-defense, provocation, or diminished responsibility.
Tennessee currently has no law specifically prohibiting the strategy.
Kayla Gore, executive director of Memphis-based nonprofit My Sistah’s House, expressed concern about the implications for Black transgender women.
Gore warned that treating a transgender woman’s identity as evidence relevant to a defendant’s fear could have consequences extending beyond an individual courtroom.
The ruling comes amid continuing efforts by LGBTQ+ advocates to eliminate panic defenses nationwide, arguing that a person’s identity should never independently establish a justification for violence.
For Lee’s family, the decision means another trial more than four years after her death. For transgender advocates, it raises a broader question about whether longstanding prejudices can continue influencing how courts evaluate violence against transgender people.
