State v. John T. Bragg, 334 A.3d 184

John Bragg was involved in a violent altercation with Lorenza Fletcher and Daquan Anderson in an apartment in Trenton, claiming the apartment was his dwelling via an informal sublease.
Both Bragg and the other parties each claimed the other was the initial aggressor during the fight; all sustained serious injuries.
Bragg was charged with multiple crimes, including attempted murder and aggravated assault—charges to which self-defense was relevant.
At trial, the prosecution emphasized Bragg’s alleged duty to retreat, arguing he should have left the apartment instead of using deadly force.
The trial court instructed the jury on the general duty to retreat but did not explain the “castle doctrine” exception (which removes the duty to retreat when one is in their own dwelling, unless they were the initial aggressor).
Bragg was convicted; the Appellate Division affirmed, citing the lack of evidence the apartment was his dwelling and that the jury deemed him the aggressor. The issue before the Supreme Court was whether the omission of the castle doctrine from jury instructions was plain error requiring reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Omission of the castle doctrine from jury charge	No error; apartment wasn't Bragg's dwelling, error harmless	Bragg had no duty to retreat from his dwelling; error was plain	Omission was plain error; jury should have been instructed on exception to retreat
Application of the duty to retreat in self-defense	Bragg required to retreat since not in his own dwelling	He was in his dwelling; wasn't initial aggressor	Factual disputes about 'dwelling' and 'initial aggressor' should have gone to jury
Invited error doctrine	Defense counsel agreed to charge; cannot now object	Counsel was confused, not inducing error; no strategic conduct	No invited error barred review; jury charge error still plain error
Effect on other counts not involving self-defense	N/A	Other convictions should also be vacated	Only counts involving self-defense vacated; others remain intact

State v. Funderburg, 225 N.J. 66 (NJ 2016) (plain error standard requires reversal if error could have led to unjust result)
State v. Perry, 124 N.J. 128 (NJ 1991) (actual, honest, reasonable belief required for self-defense)
State v. Bilek, 308 N.J. Super. 1 (App. Div. 1998) (definition of "dwelling" under self-defense statutes is broad)
State v. Montalvo, 229 N.J. 300 (NJ 2017) (proper jury charges essential to fair trial)
State v. Bonano, 59 N.J. 515 (NJ 1971) (jury must decide if location was defendant's dwelling for castle doctrine)
State v. Banko, 182 N.J. 44 (NJ 2004) (must accept arguably inconsistent jury verdicts)