State of Minnesota v. Julian Daniel Valdez

Summary

The court held that a defendant using force to defend another does not personally have a duty to retreat before intervening. Instead, the defense requires that the defendant subjectively believe the person in peril had no reasonable possibility of safe retreat and that belief be objectively reasonable based on information available when force was used. Because the erroneous retreat instruction may have affected the verdict and was not harmless beyond a reasonable doubt, the court affirmed the reversal of the conviction and remand for a new trial.