The State Supreme Court of Hawaii ruled that a man convicted of punching his stepson should have been allowed to raise parental discipline as a defense in his trial. The trial court rejected that defense because the boy’s nose was broke by the defendant who wanted him to clean a carpet stain. The case is remanded back to the trial court for a new trial.

The defense requested a jury instruction on parental discipline defense . In Hawaii , the law provides such a defense.

In order to invoke the parental discipline defense, a defendant is required to make a showing that the record contained some evidence supporting the following elements:

(1) [the defendant] was a parent, guardian, or other person as described in HRS § 703-309(1); (2) [the defendant] used force against a minor for whose care and supervision he was responsible; (3) his [or her] use of force was with due regard to the age and size of the recipient and reasonably related to the purpose of safeguarding or promoting the welfare of the minor, including the prevention or punishment of misconduct; and (4) the force used was not designed to cause, or known to create a risk of causing, substantial bodily injury, disfigurement, extreme pain or mental distress, or neurological damage.
Tennessee has no such defense that is contained in the Tennessee Pattern Jury Instructions.