People v. Riddle
Supreme Court of Michigan
649 N.W.2d 30 (2002)
Marcel Riddle (defendant) shot and killed Robin Carter in the yard outside his own home during a dispute; he claimed he believed Carter had a gun. Riddle asked the court to instruct the jury that there is no duty to retreat before using self-defense in one's own home; the court instead instructed that the jury could consider whether Riddle could have safely retreated, while also explaining he need not retreat if he honestly and reasonably believed deadly force was immediately necessary. The jury convicted Riddle of second-degree murder, and he appealed the refusal to give a castle-doctrine instruction.
Whether the castle-doctrine exception to the duty to retreat applies to the open curtilage surrounding a home.