Brown v. Eplett

Dist. Ct. did not err in denying defendant’s habeas petition that challenged his conviction on charge of first-degree reckless injury by use of dangerous weapon, arising out of incident, where defendant stabbed his cousin in head with knife during heated argument that occurred outside of defendant’s home during barbecue to which victim and his wife had been invited. While defendant argued that trial court deprived him of due process by refusing to give jury castle doctrine instruction as part of his self-defense theory, any error was harmless, where state court could properly find that rational jury could have come to same conclusion absent said error, since jury could readily have rejected defendant’s version of facts that victim had confronted him in defendant’s driveway (so as to support giving of castle doctrine instruction) and credited testimony of other witnesses and certain physical evidence that indicated that defendant had confronted victim in street. Record also contained evidence that defendant was aggressor in incident and had made threats to kill victim and victim’s wife. Fact that jury acquitted defendant of attempted murder charge did not require finding that jury had necessarily credited his version of facts.