Andres Castillo, Petitioner v. the People of the State of Colorado, Respondent.

Summary

The court held that the trial court improperly instructed the jury on the initial-aggressor exception to self-defense because no evidence showed that Castillo initiated the physical conflict by using or threatening imminent unlawful force. The instructional error was not harmless because the prosecutor extensively relied on the instruction during closing argument, so Castillo was entitled to a new trial. The court did not decide whether the separate provocation instruction was harmless; Justice Coats, joined by Justice Boatright, dissented, arguing that the jury should have received the complete statutory self-defense framework and decided the factual sequence for itself.