People v. Richardson, 490 Mich. 115

Richardson shot two neighbors on his porch after a confrontation involving a baseball bat and threats, claiming self-defense.
Prior neighbor disputes and harassment contextualize the incident; Abrams and Dinwiddie showed up at Richardson’s home with a bat.
Richardson was on the porch with his wife inside; victims were in Richardson’s yard or near the porch when shot.
Victims Abrams and Dinwiddie were injured; a medical report suggested a back or rear exit wound for Dinwiddie, with both under the influence of substances.
Defendant was charged with multiple counts including assault with intent to murder and felony-firearm; jury convicted on two GBH-like counts and felony-firearm, and acquittal on others remained unresolved at trial.
The trial court instructed on self-defense using CJI2d 7.16, including a general duty to retreat with exceptions for home, curtilage, and imminent deadly threat.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the retreat instruction was proper given the castle doctrine	Richardson contends the instruction allowed retreat to be a factor despite no duty to retreat in the dwelling.	Richardson argues the porch/curtilage place him in a dwelling, eliminating any retreat duty under the facts.	No reversible error; instruction was proper and conveyed no duty to retreat where in home/curtilage.
Whether porch/curtilage status renders retreat irrelevant	Richardson asserts the porch is his home, so retreat should not be considered.	The court should have instructed that there is no retreat duty due to dwelling/curtilage status under the castle doctrine.	Porch is part of dwelling; defendant had no duty to retreat; retreat should not be considered.
Whether the instructional error was plain, and prejudicial	The error affected the defendant’s self-defense claim and trial fairness.	Any error was not plain or prejudicial given the overall instruction and evidence.	Not plain error; no outcome-determinative prejudice established; convictions affirmed.

Pond v People, 8 Mich 150 (Mich. 1860) (castle doctrine and no retreat in dwelling)
Riddle, 467 Mich 116 (Mich. 2002) (castle doctrine; retreat not a factor in dwelling; curtilage limits)
Petrella, 424 Mich 221 (Mich. 1985) (jury instructions not binding when not tailored to case)
Carines, 460 Mich 750 (Mich. 1999) (plain error standard for instructional errors)
People v Kelly, 423 Mich 261 (Mich. 1985) (instructional completeness; take instructions as a whole)