People v. Aiken

Facts

Aiken (Defendant) and his neighbor had lived in the same Bronx apartment building for nearly forty years. Until 1995, the two had been friendly and close. After one heated verbal exchange between Defendant and the neighbor in 1997, the neighbor stabbed Defendant in the back, hospitalizing him for two days. Thereafter, the neighbor repeatedly threatened to shoot, stab, or otherwise injure Defendant. After arguing through a shared bedroom wall one evening, Defendant took a metal pipe and knocked an indentation into his side of the wall. The neighbor then left his apartment to open the apartment building’s front door for police. When the neighbor came back down the shared, common hallway, he encountered Defendant who stood in his apartment doorway, still holding the metal pipe. The neighbor went up closely to Defendant and said he was going to kill him. Believing he was about to be stabbed again, Defendant struck the neighbor on the head and killed him. Defendant was charged with murder. At trial, defense counsel requested that the court instruct the jury that a defendant has no duty to retreat into his home if he is in close proximity to the threshold of the home. The court denied the request and the jury convicted Defendant on a lesser charge first-degree manslaughter. The appellate division affirmed the conviction. The New York Court of Appeals granted certiorari to review.