## Facts

- In August 1997, Marcel R. Riddle shot Robin Carter in the yard of Riddle’s home after an argument involving Carter and James Billingsley.
- Billingsley testified Carter was unarmed and not advancing aggressively; Riddle went inside, retrieved a rifle, and shot Carter.
- Riddle testified he believed Carter held a gun or dark object, retrieved his rifle, and fired in self-defense.
- Carter died from the shooting.
- Riddle was charged with first-degree murder and felony-firearm and was convicted of second-degree murder and felony-firearm.

## Issues

1. Whether the trial court erred by refusing to instruct that Riddle had no duty to retreat before using deadly force in self-defense while in the yard of his home.
2. Whether the jury instructions on self-defense and retreat, taken as a whole, fairly and accurately stated Michigan common-law self-defense.

## Decision

- The Michigan Supreme Court affirmed the convictions.
- The court held the castle doctrine’s no-duty-to-retreat rule applies to attacks within the dwelling, not to the yard or curtilage.
- Because Riddle was outside his house, he was not entitled to a categorical “no duty to retreat” instruction based on the castle doctrine.
- The instructions given—permitting consideration of safe retreat but stating retreat is not required if deadly force is honestly and reasonably believed immediately necessary to prevent death or great bodily harm—fairly presented the law and did not deny a fair trial.

## Legal Principles

- Deadly force in self-defense is justified when the defendant, free from fault, honestly and reasonably believes there is imminent danger of death or great bodily harm and deadly force is necessary.
- The necessity element generally requires avoidance of deadly force when a safe and reasonable alternative exists, including an obvious and safe avenue of retreat.
- No duty to retreat applies when the defendant faces a sudden, fierce, and violent attack, or reasonably believes the attacker is about to use a deadly weapon; in those circumstances, failure to retreat is not considered in evaluating necessity.
- Under Michigan common law, the castle doctrine removes any duty to retreat only when the defendant is assaulted within the defendant’s dwelling; it does not automatically extend to the yard or curtilage.
- Jury instructions are sufficient if they fully and fairly present the issues and adequately protect the defendant’s rights, even if not in the exact form requested.

## Conclusion

The court held that Michigan’s common-law castle doctrine is confined to the dwelling itself and does not entitle a defendant to a no-retreat instruction for a shooting in the home’s yard; the self-defense instructions given adequately conveyed the governing retreat and necessity rules, so the convictions were affirmed.


People v. Riddle, 467 Mich. 116, 649 N.W.2d 30 (Mich. 2002)