Castle Doctrine - Wikipedia, The Free Encyclopedia

Castle doctrine - Wikipedia, the free encyclopedia
1 of 11
https://en.wikipedia.org/wiki/Castle_doctrine
Castle doctrine
From Wikipedia, the free encyclopedia
A Castle Doctrine (also known as a castle law or a defense of habitation law) is a legal doctrine that designates a person's abode or any legally occupied place
e.g., a vehicle or workplace, as a place in which that person has protections and immunities permitting him or her, in certain circumstances, to use force (up to
and including deadly force) to defend himself or herself against an intruder, free from legal prosecution for the consequences of the force used.[1] The term is
most commonly used in the United States, though many other countries invoke comparable principles in their laws.
A person may have a duty to retreat to avoid violence if one can reasonably do so. Castle doctrines negate the duty to retreat when an individual is assaulted in a
place where that individual has a right to be, such as within one's own home. Deadly force may be justified and a defense of justifiable homicide applicable, in
cases "when the actor reasonably fears imminent peril of death or serious bodily harm to him or herself or another".[1] The castle doctrine is not a defined law
that can be invoked, but a set of principles which may be incorporated in some form in the law of many jurisdictions.
Justifiable homicide[2] inside one's home is distinct, as a matter of law, from castle doctrine's no duty to retreat therefrom. Because the mere occurrence of
trespassingand occasionally a subjective requirement of fearis sufficient to invoke the castle doctrine, the burden of proof of fact is much less challenging
than that of justifying a homicide. With a mere justifiable homicide law, one generally must objectively prove to a trier of fact, beyond all reasonable doubt, the
intent in the intruder's mind to commit violence or a felony. It would be a misconception of law to infer that because a state has a justifiable homicide provision
pertaining to one's domicile, it has a castle doctrine, exonerating any duty whatsoever to retreat therefrom. The use of this legal principle in the United States
has been controversial in relation to a number of cases in which it has been invoked, including the deaths of Japanese exchange student Yoshihiro Hattori and
Scottish businessman Andrew de Vries.
Contents
1 History
1.1 In early America
1.2 On the American frontier
1.3 Current position
2 Conditions of use
2.1 Immunity from civil lawsuit
2.2 Duty to retreat
2.3 Stand-your-ground
2.4 Culpability of intruder
3 State-by-state positions in the United States
3.1 States with a castle law
3.2 States with weak or no specific castle law
4 Outside the USA
4.1 Australia
4.2 Canada
4.3 England and Wales
4.4 Germany
4.5 Ireland
4.6 Israel
4.7 Italy
5 See also
5.1 History
5.2 Related sayings
6 Notes
History
The legal concept of the inviolability of the home has been known in Western civilization since the age of the Roman Republic.[3] In English common law the
term is derived from the dictum that "an Englishman's home is his castle" (see Semayne's case). This concept was established as English law by the 17th
century jurist Sir Edward Coke, in his The Institutes of the Laws of England, 1628:[4]
For a man's house is his castle, et domus sua cuique est tutissimum refugium [and each man's home is his safest refuge].[4]
English common law came with colonists to the New World, where it has become known as the castle doctrine.[4] The term has been used in England to imply a
person's absolute right to exclude anyone from his home, although this has always had restrictions, such as bailiffs having increasing powers of entry since the
late-20th century.[5]
According to 18th-century Presbyterian minister and biblical commentator Matthew Henry, the prohibition of murder found in the Old Testament contains an
exception for legitimate self-defense. A home defender who struck and killed a thief caught in the act of breaking in at night was not guilty of bloodshed. If a
thief is caught breaking in and is struck so that he dies, the thief owes no blood-debt to the home-defender; but if the thief lives, he owes a blood-debt to the
7/16/2016 1:49 AM
2 of 11
home-defender and must make restitution.[6][7]
In early America
By the 18th century, many US state legal systems began by importing English common law such as Acts of Parliament
of 2 Ed. III (Statute of Northampton), and 5 Rich. II (Forcible Entry Act 1381) in law since 1381which imposed
criminal sanctions intending to discourage the resort to self-help.[8][9] This required a threatened party to retreat,
whenever property was "involved" and resolve the issue by civil means.
Then as now, there were English politicians who were for or against the use of self-help over state-help. William
Blackstone, in Book 4, Chapter 16[10] of his Commentaries on the Laws of England,[11] proclaims that the laws "leave
him (the inhabitant) the natural right of killing the aggressor (the burglar)" and goes on to generalize in the following
words:
"Trespassers will be shot" sign
And the law of England has so particular and tender a regard to the immunity of a man's house, that it stiles
it his castle, and will never suffer it to be violated with immunity: agreeing herein with the sentiments of
ancient Rome, as expressed in the works of Tully;[12] quid enim sanctius, quid omni religione munitius,
quam domus uniusquisque civium?[13] For this reason no doors can in general be broken open to execute
any civil process; though, in criminal causes, the public safety supersedes the private. Hence also in part
arises the animadversion of the law upon eaves-droppers, nuisancers, and incendiaries: and to this principle
it must be assigned, that a man may assemble people together lawfully without danger of raising a riot, rout,
or unlawful assembly, in order to protect and defend his house; which he is not permitted to do in any other
case.
William Blackstone, Commentaries on the Laws of England
Not only was the doctrine considered to justify defense against neighbors and criminals, but any of the Crown's agents who attempted to enter without a proper
warrant as well. It should be noted that prohibitions of the Fourth Amendment to the United States Constitution share a common background with current castle
doctrine laws.
In 1841, The Preemption Act was passed to "appropriate the proceeds of the sales of public lands... and to grant 'pre-emption rights' to individuals" who were
already living on federal lands (commonly referred to as "squatters"). During this same period, claim clubs sprung up all over the US advocating vigilance and
the castle doctrine. This was in concurrence with the culture of manifest destiny which led to westward expansion and the American Indian Wars, the last of
which ended by the 1920s.
On the American frontier

On the American frontier, the doctrine of no duty to retreat extended outside a residence. It asserted that a man in an altercation that he did not provoke was not
obliged to flee from his attacker, but was free to stand his ground and defend himself. A state Supreme Court justice wrote in 1877,[14]
Indeed, the tendency of the American mind seems to be very strongly against the enforcement of any rule which requires a person to flee when
assailed.
American West historian Richard M. Brown wrote that under the circumstances, for a man in the American West to flee under such circumstances would be
cowardly and un-American. Legendary dentist and gambler Doc Holliday successfully used this defense when he shot Billy Allen as he entered a saloon.
Holliday owed Allen $5 which Allen wanted paid and had threatened Holliday. Although Allen was unarmed at the time, Holliday had received reports that
Allen had been armed and looking for him earlier in the day. During the subsequent trial, Holliday asserted he was within his rights and the jury agreed. He was
acquitted on March 28, 1885.[14]
Current position
Today, the majority of American states have construed their statutes of forcible entry, both penal and civil, in such a manner as to abrogate the common law
privilege to use force in the recovery of possession of land.[15] A minority of states, however, have taken the view that their forcible entry statutes have not
deprived a defendant with the right to immediate possession of land of his common law privilege to use reasonable force to regain possession thereof.[16]
The term "make my day law" came to be used in the United States in about 1985 when Colorado passed a law that shielded people from any criminal or civil
liability for using force against a home invader, including deadly force.[17] (The law's nickname is a reference to the line "Go ahead, make my day" uttered by
actor Clint Eastwood's character "Dirty Harry" Callahan in the 1983 police film Sudden Impact.)
Conditions of use
Each jurisdiction incorporates the castle doctrine into its laws in different ways. The circumstance in which it may be invoked include the premises covered
(abode only, or other places too), the degree of retreat or non-deadly resistance required before deadly force can be used, etc. Typical conditions that apply to
some castle doctrine laws include:
An intruder must be making (or have made) an attempt to unlawfully or forcibly enter an occupied residence, business, or vehicle.
The intruder must be acting unlawfully (the castle doctrine does not allow a right to use force against officers of the law, acting in the course of their legal
7/16/2016 1:49 AM
3 of 11
duties).
The occupant(s) of the home must reasonably believe the intruder intends to inflict serious bodily harm or death upon an occupant of the home. Some
states apply the Castle Doctrine if the occupant(s) of the home reasonably believe the intruder intends to commit a lesser felony such as arson or burglary.
The occupant(s) of the home must not have provoked or instigated an intrusion; or, provoked/instigated an intruder's threat or use of deadly force.
In all cases, the occupant(s) of the home: must be there legally; must not be fugitives from the law, themselves, or aiding/abetting other fugitives; and must not
use force upon an officer of the law performing a legal duty.[18]
In Colorado, the make-my-day statute provides the occupant with immunity from prosecution only for force used against a person who has made an unlawful
entry into the dwelling, but not against a person who remains unlawfully in the dwelling.[19][20]
Immunity from civil lawsuit

In addition to providing a valid defense in criminal law, many laws implementing the castle doctrine, particularly those with a "stand-your-ground clause," also
have a clause which provides immunity from any civil lawsuits filed on behalf of the assailant (for damages/injuries resulting from the force used to stop them).
Without this clause, an assailant could sue for medical bills, property damage, disability, and pain & suffering as a result of the injuries inflicted by the defender;
or, if the force results in the assailant's death, his/her next-of-kin or estate could launch a wrongful death suit. Even if successfully rebutted, the defendant (the
homeowner/defender) may still have to pay high legal costs leading up to the suit's dismissal. Without criminal/civil immunity, such civil action could be used
as revenge against a lawfully acting defender (who was, originally, the assailant's victim).
Use of force in self-defense which causes damage or injuries to other, non-criminally-acting parties, may not be shielded from criminal or civil prosecution,
however.
Duty to retreat
In US jurisdictions where the castle doctrine applies, there is no duty to retreat before deadly force is used against an intruder by a person in their home or, in
some jurisdictions, just simply where the person can legally be.[21]
Stand-your-ground
Most states in the United States have stand-your-ground laws where individuals can use deadly force in any location one is legally allowed to be without first
attempting to retreat.
Culpability of intruder
In Colorado, the make-my-day statute "was not intended to justify use of physical force against persons who enter a dwelling accidentally or in good faith."[20]
In other words, "the unlawful entry element requires a culpable mental state of 'knowingly' on the part of the intruder."[22]
State-by-state positions in the United States

For each state in the US with a castle doctrine, an external link is provided to the text of the specific statute, if available. If a direct link is unavailable, for
example if the destination website uses JavaScript, the statute name and/or number is listed.
States with a castle law

Castle doctrine lays down that there is no duty to retreat from an intruder in one's home. A justifiable homicide which occurs inside one's home is distinct as a
matter of law (http://legal-dictionary.thefreedictionary.com/Matter+of+law) from castle doctrine's no duty to retreat. As such, states with justifiable homicide
provisions in pertaining to one's domicile, do not in themselves authorize indiscriminate violence thereinthe mere fact that one is trespassing is no defense per
se to justifying homicide.
In addition to the states listed below, the U.S. Territory of Guam has the Castle doctrine as law.[23]
7/16/2016 1:49 AM
4 of 11
State
Statute
Notes
"Use of force in defense of a person.
Alabama
Alaska
Arizona
Arkansas
California
13A-3-23
(a) A person is justified in using physical force upon another person in order to defend
himself or herself or a third person from what he or she reasonably believes to be the use or
imminent use of unlawful physical force by that other person, and he or she may use a
degree of force which he or she reasonably believes to be necessary for the purpose. A
person may use deadly physical force, and is legally presumed to be justified in using
deadly physical force in self-defense or the defense of another person pursuant to
subdivision (4), if the person reasonably believes that another person is: (1) Using or about
to use unlawful deadly physical force. (2) Using or about to use physical force against an
occupant of a dwelling while committing or attempting to commit a burglary of such
dwelling. (3) Committing or about to commit a kidnapping in any degree, assault in the first
or second degree, burglary in any degree, robbery in any degree, forcible rape, or forcible
sodomy. (4) In the process of unlawfully and forcefully entering, or has unlawfully and
forcefully entered, a dwelling, residence, or occupied vehicle, or federally licensed nuclear
power facility, or is in the process of sabotaging or attempting to sabotage a federally
licensed nuclear power facility, or is attempting to remove, or has forcefully removed, a
person against his or her will from any dwelling, residence, or occupied vehicle when the
person has a legal right to be there, and provided that the person using the deadly physical
force knows or has reason to believe that an unlawful and forcible entry or unlawful and
forcible act is occurring...." http://www.usacarry.com
/alabama_stand_your_ground_castle_doctrine_law.html
11.81.335
"...a person who is justified in using nondeadly force in self-defense under AS 11.81.330
may use deadly force in self-defense upon another person when and to the extent the person
reasonably believes the use of deadly force is necessary for self-defense against death,
serious physical injury, kidnapping, sexual assault, robbery in any degree... there is no duty
to leave the area if the person is(1) on premises that the person owns or leases. - See more
at: http://codes.lp.findlaw.com/akstatutes/11/11.81./04./11.81.335.#sthash.q41T1xXM.dpuf
13-411
"A. A person is justified in threatening or using both physical force and deadly physical
force against another if and to the extent the person reasonably believes that physical force
or deadly physical force is immediately necessary to prevent the other's commission of
arson of an occupied structure under section 131704, burglary in the second or first degree
under section 131507 or 131508, kidnapping under section 131304, manslaughter under
section 131103, second or first degree murder under section 131104 or 131105, sexual
conduct with a minor under section 131405, sexual assault under section 131406, child
molestation under section 131410, armed robbery under section 131904, or aggravated
assault under section 131204, subsection A, paragraphs 1 and 2. B. There is no duty to
retreat before threatening or using physical force or deadly physical force justified by
subsection A of this section. C. A person is presumed to be acting reasonably for the
purposes of this section if he the person is acting to prevent the commission of any of the
offenses listed in subsection A of this section. D. This section is not limited to the use or
threatened use of physical or deadly physical force in a person's home, residence, place of
business, land the person owns or leases, conveyance of any kind, or any other place in this
state where a person has a right to be. - See more at: http://www.azleg.gov
//FormatDocument.asp?inDoc=/legtext/47leg/2r/laws/0199.htm&Session_ID=83
[24]
The General Assembly finds that the current laws regarding self-defense and the use of
deadly physical force in self-defense or in defense of another person are adequate in that the
law explicitly does not require a person to retreat from certain life-threatening
confrontations if a person cannot do so safely. However, the General Assembly finds that
there is currently not enough protection from civil liability for a person who rightfully uses
deadly physical force in self-defense or in defense of another person. The General
Assembly finds that a more robust civil immunity statute is necessary to protect a person
from civil damages stemming from an incident when he or she lawfully uses deadly
physical force in self-defense or in defense of another person.
Penal Code 198.5
"Any person using force intended or likely to cause death or great bodily injury within his
or her residence shall be presumed to have held a reasonable fear of imminent peril of death
or great bodily injury to self, family, or a member of the household when that force is used
against another person, not a member of the family or household, who unlawfully and
forcibly enters or has unlawfully and forcibly entered the residence and the person using the
force knew or had reason to believe that an unlawful and forcible entry occurred."
[2] (http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PEN&
sectionNum=198.5.)
7/16/2016 1:49 AM
5 of 11
State
Statute
Notes
18-1-704
"...any occupant of a dwelling is justified in using any degree of physical force, including
deadly physical force, against another person when that other person has made an unlawful
entry into the dwelling, and when the occupant has a reasonable belief that such other
person has committed a crime in the dwelling in addition to the uninvited entry, or is
committing or intends to commit a crime against a person or property in addition to the
uninvited entry, and when the occupant reasonably believes that such other person might
use any physical force, no matter how slight, against any occupant." 18-1-704.5 Use of
deadly physical force against an intruder. (http://www.lexisnexis.com/hottopics/colorado
/?app=00075&view=full&interface=1&docinfo=off&searchtype=get&
search=C.R.S.+18-1-704.5)
Connecticut
Sec. 53a-20 (http://www.cga.ct.gov/2011/pub

/chap951.htm#Sec53a-20.htm)
A person in possession or control of premises, or a person who is licensed or privileged to

be in or upon such premises, is justified in using reasonable physical force upon another
person when and to the extent that he reasonably believes such to be necessary to prevent or
terminate the commission or attempted commission of a criminal trespass by such other
person in or upon such premises; but he may use deadly physical force under such
circumstances only (1) in defense of a person as prescribed in section 53a-19, or (2) when
he reasonably believes such to be necessary to prevent an attempt by the trespasser to
commit arson or any crime of violence, or (3) to the extent that he reasonably believes such
to be necessary to prevent or terminate an unlawful entry by force into his dwelling as
defined in section 53a-100, or place of work, and for the sole purpose of such prevention or
termination.
Florida
776.013 (http://www.leg.state.fl.us/statutes
/index.cfm?App_mode=Display_Statute&
URL=0700-0799/0776/Sections/0776.013.html)
Home protection; use or threatened use of deadly force; presumption of fear of death or
great bodily harm.
Georgia
16-3-23.1
No duty to retreat prior to use of force in self-defense. [3] (http://www.georgiapacking.org

/GaCode/?title=16&chapter=3&section=23.1)
Hawaii
703-304 (http://www.capitol.hawaii.gov
/hrscurrent/Vol14_Ch0701-0853/HRS0703
/HRS_0703-0304.HTM)
No duty to retreat from dwelling/workplace.
Idaho
18-4009 (http://law.justia.com/codes/idaho
/2005/18ftoc/180400009.html)
a justifiable homicide law in self-defense from violencemust prove intruder's intent

thereof
Illinois
720 ILCS 5 (http://www.ilga.gov/legislation

/ilcs/ilcs4.asp?DocName=072000050HArt.+7&
ActID=1876&ChapAct=720)
Use of deadly force justified. Specific legislation prevents filing claim against defender of
dwelling. Illinois has no requirement of retreat.
Indiana
IC 35-41-3-2 (http://www.in.gov/legislative
/ic/code/title35/ar41/ch3.html)
No duty to retreat from dwelling, curtilage, or occupied motor vehicle. In 2012, an

amendment was made to the code to address the issue of force against a public servant. The
amendment states: A person is not justified in using deadly force against a public servant
whom the person knows or reasonably should know is a public servant unless: (1) the
person reasonably believes that the public servant is: (A) acting unlawfully; or (B) not
engaged in the execution of the public servant's official duties; and (2) the force is
reasonably necessary to prevent serious bodily injury to the person or a third person.
Iowa
704.1 (http://search.legis.state.ia.us
/NXT/iclink.htm?c=704$s=1$)
No duty to retreat from home or place of business in defense of self or a "third party".
Kentucky
KRS 503.055 (http://www.lrc.ky.gov/statutes

/statute.aspx?id=19670)
No duty to retreat from dwelling, residence or occupied vehicle.
Louisiana
LA RS 14:20 (http://www.legis.state.la.us
/lss/lss.asp?doc=78338)
(4)(a) When committed by a person lawfully inside a dwelling, a place of business, or a

motor vehicle as defined in R.S. 32:1(40), against a person who is attempting to make an
unlawful entry into the dwelling, place of business, or motor vehicle, or who has made an
unlawful entry into the dwelling, place of business, or motor vehicle, and the person
committing the homicide reasonably believes that the use of deadly force is necessary to
prevent the entry or to compel the intruder to leave the premises or motor vehicle.
Maine
104 (http://janus.state.me.us/legis/statutes
/17-a/title17-asec104.html)
Deadly force justified to terminate criminal trespass AND another crime within home, or to
stop unlawful and imminent use of deadly force, or to effect a citizen's arrest against deadly
force; duty to retreat not specifically removed[25]
Colorado
Maryland
See Maryland self-defense. Case-law, not statute, incorporates the common law castledoctrine into Maryland self-defense law. Invitees or guests may have duty to retreat based
on mixed case law.[26]
Massachusetts
Section 8A. In the prosecution of a person who is an occupant of a dwelling charged with
killing or injuring one who was unlawfully in said dwelling, it shall be a defense that the
occupant was in his dwelling at the time of the offense and that he acted in the reasonable
belief that the person unlawfully in said dwelling was about to inflict great bodily injury or
278-8a (http://www.mass.gov/legis/laws/mgl
/278-8a.htm)
7/16/2016 1:49 AM
6 of 11
State
Statute
Notes
death upon said occupant or upon another person lawfully in said dwelling, and that said
occupant used reasonable means to defend himself or such other person lawfully in said
dwelling. There shall be no duty on said occupant to retreat from such person unlawfully in
said dwelling.
768.21c Use of deadly force by individual in own dwelling; "dwelling" defined.
Michigan
768.21c (http://www.legislature.mi.gov
/%28S%28yn5bw45msck2da2vgll4o4rt%29%29
/mileg.aspx?page=GetObject&objectname=mcl768-21c)
Minnesota
609.065 (http://www.revisor.leg.state.mn.us
/statutes/?id=609.065)
Mississippi
MS Code 97-3-15
(1) In cases in which section 2 of the self-defense act does not apply, the common law of
this state applies except that the duty to retreat before using deadly force is not required if
an individual is in his or her own dwelling or within the curtilage of that dwelling.
(2) As used in this section, "dwelling" means a structure or shelter that is used permanently
or temporarily as a place of abode, including an appurtenant structure attached to that
structure or shelter.[27]
No duty to retreat before using deadly force to prevent a felony in one's place of abode; no
duty to retreat before using deadly force in self-defense in one's place of abode [28]) This
isn't as clear as it appears, however. There are four cases in Minnesota where duty of retreat
was upheld.[29]
(3) A person who uses defensive force shall be presumed to have reasonably feared
imminent death or great bodily harm, or the commission of a felony upon him or another or
upon his dwelling, or against a vehicle which he was occupying, or against his business or
place of employment or the immediate premises of such business or place of employment,
if the person against whom the defensive force was used, was in the process of unlawfully
and forcibly entering, or had unlawfully and forcibly entered, a dwelling, occupied vehicle,
business, place of employment or the immediate premises thereof or if that person had
unlawfully removed or was attempting to unlawfully remove another against the other
person's will from that dwelling, occupied vehicle, business, place of employment or the
immediate premises thereof and the person who used defensive force knew or had reason to
believe that the forcible entry or unlawful and forcible act was occurring or had occurred.
This presumption shall not apply if the person against whom defensive force was used has a
right to be in or is a lawful resident or owner of the dwelling, vehicle, business, place of
employment or the immediate premises thereof or is the lawful resident or owner of the
dwelling, vehicle, business, place of employment or the immediate premises thereof or if
the person who uses defensive force is engaged in unlawful activity or if the person is a law
enforcement officer engaged in the performance of his official duties;
(4) A person who is not the initial aggressor and is not engaged in unlawful activity shall
have no duty to retreat before using deadly force under subsection (1) (e) or (f) of this
section if the person is in a place where the person has a right to be, and no finder of fact
shall be permitted to consider the person's failure to retreat as evidence that the person's use
of force was unnecessary, excessive or unreasonable.
(5) (a) The presumptions contained in subsection (3) of this section shall apply in civil
cases in which self-defense or defense of another is claimed as a defense.[30]
Missouri
563.031 (http://www.moga.mo.gov/statutes
/C500-599/5630000031.HTM)
Extends to any building, inhabitable structure, or conveyance of any kind, whether the
building, inhabitable structure, or conveyance is temporary or permanent, mobile or
immobile (e.g., a camper, RV or mobile home), which has a roof over it, including a tent,
and is designed to be occupied by people lodging therein at night, whether the person is
residing there temporarily, permanently or visiting (e.g., a hotel or motel), and any vehicle.
The defense against civil suits is absolute and includes the award of attorney's fees, court
costs, and all reasonable expenses incurred by the defendant in defense of any civil action
brought by a plaintiff.
45-3-103. Use of force in defense of occupied structure.
Montana
[4] (http://leg.mt.gov/bills/mca/45
/3/45-3-103.htm) 45-3-103
Nevada
200.120 (http://www.leg.state.nv.us/NRS/NRS200.html#NRS200Sec120)
(1) A person is justified in the use of force or threat to use force against another when and
to the extent that the person reasonably believes that the use of force is necessary to prevent
or terminate the other person's unlawful entry into or attack upon an occupied structure.
(2) A person justified in the use of force pursuant to subsection (1) is justified in the use of
force likely to cause death or serious bodily harm only if:
(a) the entry is made or attempted and the person reasonably believes that the force is
necessary to prevent an assault upon the person or another then in the occupied structure; or
(b) the person reasonably believes that the force is necessary to prevent the commission of a
forcible felony in the occupied structure.
200.120.
1. Justifiable homicide is the killing of a human being in necessary self-defense, or in
7/16/2016 1:49 AM
7 of 11
State
Statute
Notes
defense of habitation, property or person, against one who manifestly intends or endeavors,
by violence or surprise, to commit a felony, or against any person or persons who
manifestly intend and endeavor, in a violent, riotous, tumultuous or surreptitious manner, to
enter the habitation of another for the purpose of assaulting or offering personal violence to
any person dwelling or being therein.
2.A person is not required to retreat before using deadly force as provided in subsection 1
if the person:
(a)Is not the original aggressor;
(b)Has a right to be present at the location where deadly force is used; and
(c)Is not actively engaged in conduct in furtherance of criminal activity at the time deadly
force is used.
New
Hampshire
[5] (http://www.gencourt.state.nh.us/RSA/html
/LXII/627/627-4.htm)
Not required to retreat if he or she is within his or her dwelling, its curtilage, or anywhere
he or she has a right to be, and was not the initial aggressor. An individual may respond to a
threat of serious bodily injury or death by displaying a firearm or other method of
self-defense. Deadly force is justified if the aggressor is about to use unlawful, deadly
force, is likely to use any unlawful force against a person present while committing or
attempting to commit a burglary, is committing or about to commit kidnapping or a forcible
sex offense, or is likely to use any unlawful force in the commission of a felony against the
individual within their dwelling or its curtilage.
New Jersey
[6] (http://law.onecle.com/new-jersey/2c-thenew-jersey-code-of-criminal-justice/3-4.html)
Retreat required if actor knows he can avoid necessity of deadly force in complete safety,
etc. except not obliged to retreat from dwelling, unless the initial aggressor
New York
PL 35.15(2)(a)(i) (http://law.onecle.com
/new-york/penal/PEN035.15_35.15.html)
Retreat required if actor knows that with complete personal safety, to oneself and others, he
or she may avoid the necessity of using deadly force by retreating, except that the actor is
under no duty to retreat if he or she is in his or her dwelling and not the initial aggressor.
Use of force in defense of person; relief from criminal or civil liability.
North
Carolina
1451.3 (http://www.ncleg.net
/enactedlegislation/statutes/html/bysection
/chapter_14/gs_14-51.3.html)
(a) A person is justified in using force, except deadly force, against another when and to the
extent that the person reasonably believes that the conduct is necessary to defend himself or
herself or another against the other's imminent use of unlawful force. However, a person is
justified in the use of deadly force and does not have a duty to retreat in any place he or she
has the lawful right to be if either of the following applies: (1) He or she reasonably
believes that such force is necessary to prevent imminent death or great bodily harm to
himself or herself or another. (2) Under the circumstances permitted pursuant to G.S.
1451.2. (http://www.ncleg.net/enactedlegislation/statutes/html/bysection/chapter_14
/gs_14-51.2.html) (b) A person who uses force as permitted by this section is justified in
using such force and is immune from civil or criminal liability for the use of such force,
unless the person against whom force was used is a law enforcement officer or bail
bondsman who was lawfully acting in the performance of his or her official duties and the
officer or bail bondsman identified himself or herself in accordance with any applicable law
or the person using force knew or reasonably should have known that the person was a law
enforcement officer or bail bondsman in the lawful performance of his or her official duties.
(2011268, s. 1.)
When deadly force is used in lawful self-defense, or in lawful defense of others, if such
force is necessary to protect the actor or anyone else against death, serious bodily injury, or
the commission of a felony involving violence, An individual is not required to retreat
within or from that individual's dwelling or place of work or from an occupied motor home
or travel trailer, unless the individual was the original aggressor or is assailed by another
individual who the individual knows also dwells or works there or who is lawfully in the
12.1-05-07. [7] (http://www.legis.nd.gov/cencode
North Dakota
motor home or travel trailer. Also, deadly force is permitted in defense of property when
/t12-1c05.pdf?20131030212707)
used by an individual in possession or control of a dwelling, place of work, or an occupied
motor home or travel trailer, or by an individual who is licensed or privileged to be there, if
the force is necessary to prevent commission of arson, burglary, robbery, or a felony
involving violence upon or in the dwelling, place of work, or occupied motor home or
travel trailer, and the use of force other than deadly force for these purposes would expose
any individual to substantial danger of serious bodily injury.
Ohio
Oregon
127 SB 184 (http://archives.legislature.state.oh.us Extends to vehicles of self and immediate family; effective September 9, 2008.[31] Section
/bills.cfm?ID=127_SB_184)
2901.09
ORS [8] (https://www.oregonlegislature.gov

/bills_laws/ors/ors161.html)
Use of force justifiable in a range of scenarios without a duty to retreat specified. Oregon
Supreme Court affirmed in State of Oregon v. Sandoval
(http://www.publications.ojd.state.or.us/docs/S53457.htm) that the law "sets out a specific
set of circumstances that justify a person's use of deadly force (that the person reasonably
believes that another person is using or about to use deadly force against him or her) and
does not interpose any additional requirement (including a requirement that there be no
7/16/2016 1:49 AM
8 of 11
State
Statute
Notes
means of escape)."
18 Pa.C.S. Chapter 5 505

(http://www.legis.state.pa.us/CFDOCS/Legis
Pennsylvania /PN/Public/btCheck.cfm?txtType=HTM&
sessYr=2011&sessInd=0&billBody=H&
billTyp=B&billNbr=0040)
Rhode Island
The most recent version of Pennsylvanias Castle Doctrine legislation was signed into law
in June 2011. The law extends the right to self-defense up to and including deadly force in a
victims dwelling (now including any attached porch, deck or patio), occupied vehicle, or
any other dwelling or vehicle that the victim legally occupies. A place of work is included
in the "castle" provision under certain circumstances. Use of deadly force is justifiable if
the "castle" area in the event that an assailant is "unlawfully and forcefully entering" or has
entered the "castle" area. Deadly force is also justifiable, subject to certain provisions, if a
person that legally enters the "castle" goes on to unlawfully attack a victim (when the
victim is resonably in fear of his/her life) or if the attacker attempts to kidnap anyone who
legally occupies the "castle". The victim must be in "legal possession" of a firearm or other
weapon to be justified in the use of that weapon. Use of deadly force to protect an innocent
third person is generally allowed in circumstances where the provisions for justifiable
self-defense are met. Victims who justifiably use force to defend themselves under the
provisions of the law are immune from civil liability for any injuries sustained by the
attacker during the incident. The new legislation also contains a stand your ground
provision when outside the "castle". Outside "castle areas" there is no duty to retreat if
confronted with a weapon.
11-8-8 (http://www.rilin.state.ri.us/Statutes
/TITLE11/11-8/11-8-8.HTM)
(a) A person is justified in using deadly force against another:
Texas
Penal Code Sec. 9.32

(http://www.statutes.legis.state.tx.us/Docs/PE
/htm/PE.9.htm#9.32)
(1) if the actor would be justified in using force against the other under Section 9.31; and
(2) when and to the degree the actor reasonably believes the deadly force is immediately
necessary: (A) to protect the actor against the other's use or attempted use of unlawful
deadly force; or (B) to prevent the other's imminent commission of aggravated kidnapping,
murder, sexual assault, aggravated sexual assault, robbery, or aggravated robbery. (b) The
actor's belief under Subsection (a)(2) that the deadly force was immediately necessary as
described by that subdivision is presumed to be reasonable if the actor: (1) knew or had
reason to believe that the person against whom the deadly force was used: (A) unlawfully
and with force entered, or was attempting to enter unlawfully and with force, the actor's
occupied habitation, vehicle, or place of business or employment; (B) unlawfully and with
force removed, or was attempting to remove unlawfully and with force, the actor from the
actor's habitation, vehicle, or place of business or employment; or (C) was committing or
attempting to commit an offense described by Subsection (a)(2)(B); (2) did not provoke the
person against whom the force was used; and (3) was not otherwise engaged in criminal
activity, other than a Class C misdemeanor that is a violation of a law or ordinance
regulating traffic at the time the force was used. (c) A person who has a right to be present
at the location where the deadly force is used, who has not provoked the person against
whom the deadly force is used, and who is not engaged in criminal activity at the time the
deadly force is used is not required to retreat before using deadly force as described by this
section. (d) For purposes of Subsection (a)(2), in determining whether an actor described by
Subsection (c) reasonably believed that the use of deadly force was necessary, a finder of
fact may not consider whether the actor failed to retreat.
76-2-405. Amended by Chapter 252, 1985 General Session. Force in defense of habitation.
(1) A person is justified in using force against another when and to the extent that he
reasonably believes that the force is necessary to prevent or terminate the other's unlawful
entry into or attack upon his habitation; however, he is justified in the use of force which is
intended or likely to cause death or serious bodily injury only if: (a) the entry is made or
attempted in a violent and tumultuous manner, surreptitiously, or by stealth, and he
reasonably believes that the entry is attempted or made for the purpose of assaulting or
offering personal violence to any person, dwelling, or being in the habitation and he
reasonably believes that the force is necessary to prevent the assault or offer of personal
violence; or (b) he reasonably believes that the entry is made or attempted for the purpose
of committing a felony in the habitation and that the force is necessary to prevent the
commission of the felony. (2) The person using force or deadly force in defense of
habitation is presumed for the purpose of both civil and criminal cases to have acted
reasonably and had a reasonable fear of imminent peril of death or serious bodily injury if
the entry or attempted entry is unlawful and is made or attempted by use of force, or in a
violent and tumultuous manner, or surreptitiously or by stealth, or for the purpose of
committing a felony.
Utah
[9] (http://le.utah.gov/xcode/Title76/Chapter2
/76-2-S405.html)
West Virginia
55-7-22.
[10] (http://www.legis.state.wv.us/wvcode
/ChapterEntire.cfm?chap=55&art=7&section=22) (a) A lawful occupant within a home or other place of residence is justified in using
7/16/2016 1:49 AM
9 of 11
State
Statute
Notes
reasonable and proportionate force, including deadly force, against an intruder or attacker to
prevent a forcible entry into the home or residence or to terminate the intruder's or attacker's
unlawful entry if the occupant reasonably apprehends that the intruder or attacker may kill
or inflict serious bodily harm upon the occupant or others in the home or residence or if the
occupant reasonably believes that the intruder or attacker intends to commit a felony in the
home or residence and the occupant reasonably believes deadly force is necessary.
(b) A lawful occupant within a home or other place of residence does not have a duty to
retreat from an intruder or attacker in the circumstances described in subsection (a) of this
section.
Wisconsin
[11] (https://docs.legis.wisconsin.gov
/2011/proposals/ab69)
Wyoming
[12] (http://trib.com/news/state-and-regional
/gov-signs-castle-doctrinebill/article_65c56e68-273a-57fc-90eae3052bac0527.html)
Assembly Bill 69, signed December 7, 2011) The civil immunity became Sec. 895.62,
Wis.Stats. and the criminal immunity became Sec. 939.48, Wis.Stats.
States with weak or no specific castle law

These states uphold castle doctrine in general, but may rely on case law instead of specific legislation, may enforce a duty to retreat, and may impose specific
restrictions on the use of deadly force:
District of Columbia
Nebraska - a bill was introduced in January 2012 that allowed deadly force against a person who broke into a house or occupied vehicle or who tried to
kidnap someone from a house or vehicle; however, the bill was revised to include only an affirmative defense from lawsuits pertaining to justifiable use
of force.[32][33]
New Mexico - Limited Castle Doctrine for self-defense inside one's home established by court precedence in State v. Couch (1946). No civil immunity
from potential lawsuits by the aggressor or surviving relatives. In 2011, two bills (House Bill 228 and Senate Bill 29) would have granted civil immunity
to individuals who lawfully use lethal force in self-defense, both bills died in their respective chambers of the New Mexico Legislature.
South Dakota - "Homicide is justifiable if committed by any person while resisting any attempt to murder such person, or to commit any felony upon him
or her, or upon or in any dwelling house in which such person is." See South Dakota Codified Laws 22-16-34 (2005).[34]
Vermont[35]
Outside the USA

Australia
Australian states have differing self-defence laws. Under South Australian law, the general defence appears in s15(1) Criminal Law Consolidation Act 1935
(SA) for defending a person's life, and s15A(1) for defending property, subject to a hybrid test, i.e. the defendant honestly believed the threat to be imminent
and made an objectively reasonable and proportionate response to the circumstances as the accused subjectively perceived them.[36]
In July 2003, the Rann Government (SA) introduced laws allowing householders to use "whatever force they deem necessary" when confronted with a home
invader. Householders who kill or injure a home invader escape prosecution provided they can prove they had a genuine belief that it was necessary to do so to
protect themselves or their family. The law was strongly opposed by then-Director of Public Prosecutions Paul Rofe, QC, and lawyer Marie Shaw, who is now a
District Court Judge.[37]
Canada
By court ruling in 2011, a resident is permitted to use "reasonable and necessary" force in subduing an intruder in his or her private domicile or business. By
definition, killing the intruder is only an option if non-lethal means cannot be carried out, and excessive force with obvious intent to kill is not necessarily
defensible in court.[38]
England and Wales

In English common law a defendant may seek to avoid criminal or civil liability by claiming that he acted in self-defence.[39] This requires the jury to determine
whether the defendant believed that force was necessary to defend him or herself, his or her property, or to prevent a crime, and that the force used was
reasonable.[40] While there is no duty to retreat from an attacker and failure to do so is not conclusive evidence that a person did not act in self-defence, it may
still be considered by the jury as a relevant factor when assessing the merits of a self-defence claim.[39] The common law duty to retreat was repealed by the
Criminal Law Act 1967. This duty never existed when a person is somewhere he has a lawful right to be, but due to the repeal, now extends to public places,
etc.
Germany
German law allows self-defense against an unlawful attack.[41] Courts have interpreted this law as applicable to home invasion, including the use of lethal force
7/16/2016 1:49 AM
against law enforcement in cases where the home owner was of the mistaken belief that the intrusion was an unlawful
attack on his life.[42]
Ireland
Under the terms of the Defence and the Dwelling Act, property owners or residents are entitled to defend themselves
with force, up to and including lethal force. Any individual who uses force against a trespasser is not guilty of an offense
if he or she honestly believes they were there to commit a criminal act and a threat to life. However, there is a further
provision which requires that the reaction to the intruder is such that another reasonable person in the same
circumstances would likely employ. This provision acts as a safeguard against grossly disproportionate use of force,
while still allowing a person to use force in nearly all circumstances.
"Trespassers will be shot" sign in

England
The law was introduced in response to DPP v. Padraig Nally.[43][44] The Act largely places previous Irish common law
jurisprudence regarding self-defense on a statutory footing.[45]
Israel
Israeli law allows property owners to defend themselves with force.[46] This law was introduced in response to the trial of Shai Dromi, an Israeli farmer who
shot Arab intruders on his farm late at night.[47]
Italy
Italy passed a law in 2005 that would allow property owners to defend themselves with force.[48] The law practical application is however highly controversial:
Italian judiciary system is rather complex and using force is, more often than not, not recommended at all, since the property owner might get sued for
disproportionate use of force.[49]
See also
Duty to retreat, obligation to withdraw rather than attack, overridden by castle doctrine
Justifiable homicide, the blameless killing of a person, such as in self-defense.
Stand-your-ground law, which applies the castle doctrine to any place.
Self-defence (Australia)
Squatting in the United States
Trespasser
History
Claim club
Related sayings
a man's home is his castle
an Englishman's home is his castle
Notes
1. "Assembly, No. 159, State of New Jersey, 213th Legislature, The "New Jersey
Self Defense Law" " (PDF). May 6, 2008. Retrieved 2009-03-19. "The Castle
Doctrine is a long-standing American legal concept arising from English
Common Law that provides that one's abode is a special area in which one
enjoys certain protections and immunities, that one is not obligated to retreat
before defending oneself against attack, and that one may do so without fear of
prosecution."
2. Black's Law Dictionary (http://thelawdictionary.org/homicide-justifiable
/#ixzz2aUEbR0HM): This term applies to the blameless killing of a person, such
as in self-defense.
3. Numa Denis Fustel de Coulanges, The Ancient City, 50. "To enter this house
with any malevolent intention was a sacrilege. The domicile was inviolable."
4. "An Englishman's home is his castle". Phrases.org.uk. Retrieved 2012-01-11.
5. Philip Johnston (11 January 2009). "An Englishman's home is no longer his
castle". London: Telegraph. Retrieved 2012-01-11.
6. Exodus 22:2-3
7. Exodus 22:1-3 (http://www.mechon-mamre.org/p/pt/pt0222.htm)
8. Dickinson v. Maguire, 9 Cal. 46 (http://www.lexisnexis.com/clients/CACourts/),
The Chief Justice of California during the ruling was David S. Terry, who
ironically, was later killed by order of Associate Supreme Court Justice Field
under the guise of self-defense.
9. Daluiso v. Boone , 71 Cal.2d 484 (http://scocal.stanford.edu/opinion/daluisov-boone-27416) for English common law history
10 of 11
10. Blackstone's Commentaries - Book the Fourth - Chapter the Sixteenth : Of

Offenses Against the Habitations of Individuals (http://www.yale.edu/lawweb
/avalon/blackstone/bk4ch16.htm)
11. Some doctrines would be hotly debated as law as applied in the young
post-revolution United States. Example: "That the King can do no wrong, is a
necessary and fundamental principle of the English constitution."
12. "Tully" was once a common abbreviation for Marcus Tullius Cicero.
13. What is more sacred, what more strongly guarded by every holy feeling, than a
man's own home?
14. Jay, Roger (August 14, 2006). "Spitting Lead in Leadville: Doc Holliday's Last
Stand". HistoryNet. Wild West Magazine. Retrieved 13 April 2015.
15. 1 Harper and James, op.cit. supra, at 3.15, p. 258; Prosser, Law of Torts (3d ed.
1964) 23, p. 125. See e.g., Mason v. Hawes (1884) 52 Conn. 12, 16 [52
Am.Rep. 552]; McIntyre v. Murphy (1908) 153 Mich. 342, 346-347 [116 N.W.
1003, 1004-1005, 15 Ann.Cas. 802]; Lobdell v. Keene (1901) 85 Minn. 90, 101
[88 N.W. 426, 430]; Strauel v. Lubeley (1915) 186 Mo.App. 638, 643-644 [172
S.W. 434, 435-436]; Mosseller v. Deaver (1890) 106 N.C. 494, 496-498 [11 S.E.
529, 530, 8 L.R.A. 537, 19 Am.St.Rep. 540]; Weatherly v. Manatt (1919) 72
Okla. 138, 139-140 [179 P. 470, 471]; Walgreen Co. v. Walton (1932) 16
Tenn.App. 213, 229 [64 S.W.2d 44, 53]; Ray v. Dyer (Tex.Civ.App. 1929) 20
S.W.2d 328, 330; Buchanan v. Crites (1944) 106 Utah 428, 436 [150 [71 Cal.2d
493] P.2d 100, 103]. See also Whitney v. Brown (1907) 75 Kan. 678, 681-683
[90 P. 277, 278, 11 L.R.A. N.S. 468, 12 Ann.Cas. 768]; Rest.2d Torts, 185,
com. a.) See Daluiso v. Boone, 71 Cal.2d 484 (http://scocal.stanford.edu/opinion
7/16/2016 1:49 AM
11 of 11
/daluiso-v-boone-27416)
16. "Shorter v. Shelton, 183 Va. 819, 826-827". Supreme Court of Virginia. April 23,
1945. Retrieved 2013-07-29. "It will be observed that the statute [of forcible
entry] does not in express terms deprive the owner of the common-law right to
take possession by reasonable force of premises to which he may be entitled."
17. Dirk Johnson (June 1, 1990). " 'Make My Day': More Than a Threat". New York
Times. Retrieved 2008-06-27.
18. Reinhart, Christopher. "CASTLE DOCTRINE AND SELF-DEFENSE".
http://www.cga.ct.gov. State of Connecticut. Retrieved 8 September 2014.
External link in |website= (help)
19. People v. Drennon, 860 P.2d 589 (Colo. Ct. App. 1993)
20. People v. McNeese, 892 P.2d 304 (Colo. 1995)
21. Rhinehart, C, Castle Doctrine and Self-Defense (http://www.cga.ct.gov/2007/rpt
/2007-R-0052.htm) Connecticut General Assembly, Office of Legislative
Research.
22. People v. Zukowski, 260 P.3d 339 (Colo. Ct. App. 2011)
23. (February 10, 2014) - "BREAKING NEWS: Gov. Calvo Signs Castle Doctrine
Into Law" (http://www.guampdn.com/article/20140210/NEWS01/140210003
/BREAKING-NEWS-Gov-Calvo-signs-Castle-Doctrine-into-law). Pacific Daily
News. Retrieved February 3, 2015.
24. http://www.arkleg.state.ar.us/assembly/2015/2015R/Acts/Act1073.pdf
25. Physical force justification (http://www.mainelegislature.org/legis/statutes
/17-a/title17-Asec107.html)
26. http://house.state.md.us/2007RS/fnotes/bil_0001/sb0761.pdf
27. "Michigan Legislature - Section 768.21c". legislature.mi.gov. Retrieved
2015-03-04.
28. "State of Minnesota v. Glowacki, 630 N.W.2d 392, 402 (Minn. 2001)".
29. "No. C8-98-86. - STATE v. CAROTHERS MN Court of Appeals".
Caselaw.findlaw.com. Retrieved 2012-01-11.
30. http://web.lexisnexis.com/research/xlink?app=00075&view=full&interface=1&
docinfo=off&searchtype=get&search=Miss.+Code+Ann.+%A7+97-3-15
31. "Senate Bills Status Report of Legislation, SB 184". Retrieved 2008-08-09.
32. Moring, Rosann (March 29, 2012). "150 at rally over death of Florida teen". The
Daily Nonpariel. Retrieved 2012-04-17.
33. LTC. "Nebraska Legislature". nebraskalegislature.gov. Retrieved 2016-04-02.
34. http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&
Statute=22-16-34
35. Dustin v. Cowdry (1851) 23 Vt. 631, 639-640. Official Vermont Reports, Vol.
23, Pg. 631 (Supreme Court of Vermont reporter). 1851. Retrieved July 27,
2013. "[H]ad the present plaintiff elected to have proceeded under the statute,
there can be no doubt, he might have subjected the defendants to punishment by
way of fine, obtained restitution of the possession, and sustained an action of
trespass, and recovered three fold damages for the expulsion and detention. And
if such be the undeniable rights of the parties, under the statute, it is difficult to
see, why, if the party waive all penalty under the statute, he may not sustain
trespass qu. cl. against the defendants, the same as against any other wrong
doers. Their [defendants'] right to possession gave them no more right to enter in
that manner [by force], than if they had been mere strangers. ..."
36. "Criminal Law Consolidation (Self Defence) Amendment Act 2003" (PDF).
Government of South Australia. Retrieved 27 July 2013.
37. Accused to argue self defence | adelaidenow (http://www.news.com.au
/adelaidenow/story/0,22606,21134744-2682,00.html). News.com.au
(2007-01-28). Retrieved on 2012-08-06.
38. Hopper, Tristan. "Homeowners not required to flee intruders: court". The
National Post. Retrieved 8 August 2014.
39. "CPS Guidance on Self-defence". Retrieved 18 March 2012.
40. "CPS Guidelines on Self-Defence". Retrieved 18 March 2012.
41. "Notwehrparagraph".
42. "BGH, 02.11.2011 - 2 StR 375/11".
43. Cullen, Paul (13 January 2012). "Law lets householders use reasonable force".
The Irish Times.
44. "Law allows 'reasonable force' defending home". RT News. 13 January 2012.
45. http://www.humanrights.ie/index.php/2010/07/20/the-criminal-law-defenceand-the-dwelling-bill-2010/
46. "Knesset Passes "Dromi Law" ". Retrieved 18 March 2012.
47. Stoil, Rebecca Anna (24 June 2008). "New law allows shooting at burglars". The
Jerusalem Post. Retrieved 15 July 2009.
48. Italy approves self-defence law (http://news.bbc.co.uk/2/hi/europe/4645228.stm)
, BBCX, January 24, 2006.
49. [1] (http://www.diritto.it/docs/21686-la-riforma-della-legittima-difesa) Diritto.it,
commentary on the law
Retrieved from "https://en.wikipedia.org/w/index.php?title=Castle_doctrine&oldid=726486646"

Categories: Criminal defenses Homicide U.S. state criminal law Legal doctrines and principles Self-defense Gun politics in the United States
This page was last modified on 22 June 2016, at 14:02.
Text is available under the Creative Commons Attribution-ShareAlike License; additional terms may apply. By using this site, you agree to the Terms of
Use and Privacy Policy. Wikipedia is a registered trademark of the Wikimedia Foundation, Inc., a non-profit organization.
7/16/2016 1:49 AM

Castle Doctrine - Wikipedia, The Free Encyclopedia

Загружено:

Сведения о документе

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

Castle Doctrine - Wikipedia, The Free Encyclopedia

Загружено:

Авторское право:

Доступные форматы

Castle doctrine - Wikipedia, the free encyclopedia