In the USA, black rage refers to a purported psychological phenomenon and innovative defense proposed, but not used, for the 1994 Colin Ferguson mass murder trial. Ferguson's lawyers (Eric Nnanabu) argued that he should not be held criminally liable, for actions which broke the law, because he was overcome with rage by his perception of society's racist discrimination against Black people. Ferguson rejected the advice of his lawyer and represented himself, arguing instead that he was completely innocent. He was found guilty and imprisoned.