State v. Leidholm, Supreme Court of North Dakota, 334 N.W.2d 811 (1983), is a criminal law case distinguishing the subjective and objective standard of reasonableness in a case where a battered woman used self-protection as a defense. Janice Leidholm had killed her husband near Washburn, North Dakota and claimed self defense. The case clarifies between the defenses of justification and excuse.