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The deal in the Bias case was if the distance was two feet or two inches. The difference between murder and suicide. In a SD case, the difference between two feet and two inches is irrelevant. The danger from harm is virtually the same.
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I don't see how you could argue that GSR evidence can't be a factor. GSR is being used in the Zimmerman case as a matter of fact. You might argue the level of risk. Then try to weigh that risk against the benefit of carrying reloads. Then make your decision whether to carry reloads based on your personal assessment.
The only reason you don't see a lot of self-defense/murder cases involving reloads is just that not very many people get into shootings carrying handloads for self defense.
Any self defense criminal trial is a murder case or a manslaughter case, by the way.