State v. Baird

Summary

The Supreme Court of Minnesota held that its rule in State v. Glowacki, eliminating the duty to retreat from one's home when acting in self-defense against a co-resident, applies retroactively. The court further held that the erroneous duty-to-retreat jury instruction was plain, prejudicial error affecting substantial rights. The court affirmed the court of appeals' reversal of Jeffrey Baird's third-degree assault conviction and remand for a new trial.

Holdings

1. State v. Glowacki applies retroactively to Baird's pending criminal case.
2. The district court plainly erred by instructing the jury that Baird had a duty to retreat from his home before using self-defense against a co-resident, and the error affected substantial rights and required a new trial.

Questions Presented

1. Whether State v. Glowacki, which held that a person acting in self-defense has no duty to retreat from the person's own home even when the aggressor is a co-resident, applies retroactively to Baird's case.
2. Whether the district court's erroneous duty-to-retreat jury instruction constituted plain, prejudicial error requiring a new trial.

Disposition

affirmed