State v. Gartland

Ellen Gartland (defendant) suffered years of abuse from her husband, John. After an argument, Ellen retreated to her separate bedroom, but John followed her, threatened to hit her, and charged at her after she pointed a shotgun and told him to stop; she shot and killed him. The trial court instructed the jury that Ellen could not claim self-defense if she could have safely retreated from the house, and Ellen argued the jury should have been told she had no duty to retreat because her bedroom was a separate dwelling. The jury convicted Ellen of reckless manslaughter; she appealed but died while it was pending, and the New Jersey Supreme Court heard the case as a recurring issue.