• #Law
• #Jurisdiction

This paper comparatively analyzes the problem of mistake of justificatory facts, particularly in self-defense, from the perspectives of Korean, German, and US criminal law. US courts apply the reasonable person standard when determining the validity of a self-defense claim, while Korean and German theories adopt a more systematic and scholarly approach. The author argues that Korean criminal law scholars should pay attention to US case law to harmonize Korean law with Anglo-American law and establish a unique Korean criminal law system.