Samuel Culverson, Appellant v. the State of Nevada, Respondent

Summary

The Nevada Supreme Court reversed Culverson's first-degree murder conviction because the jury instructions improperly suggested that self-defense required actual danger and imposed a duty to retreat on a non-aggressor. The court held that reasonable belief in an imminent threat of serious bodily harm or death is sufficient, and that a non-aggressor need not retreat before using deadly force. Justice Rose, joined by Justice Springer, concurred in the reversal but would have required retreat when it could be accomplished with complete safety.