Mich. Comp. Laws » Michigan Compiled Laws / Chapter 780 / Act 309 of 2006
Michigan Compiled Laws

Mich. Comp. Laws § 780.972 (2026)

Use of deadly force by individual not engaged in commission of crime; conditions.

✓ current as of July 2026
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SELF-DEFENSE ACT


Act 309 of 2006


780.972 Use of deadly force by individual not engaged in commission of crime; conditions.

Sec. 2.

    (1) An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be with no duty to retreat if either of the following applies:

    (a) The individual honestly and reasonably believes that the use of deadly force is necessary to prevent the imminent death of or imminent great bodily harm to himself or herself or to another individual.

    (b) The individual honestly and reasonably believes that the use of deadly force is necessary to prevent the imminent sexual assault of himself or herself or of another individual.

    (2) An individual who has not or is not engaged in the commission of a crime at the time he or she uses force other than deadly force may use force other than deadly force against another individual anywhere he or she has the legal right to be with no duty to retreat if he or she honestly and reasonably believes that the use of that force is necessary to defend himself or herself or another individual from the imminent unlawful use of force by another individual.

History: 2006, Act 309, Eff. Oct. 1, 2006

Notes of Decisions
Cited in 301 cases (112 in the last 5 years), 2008–2026 · leading case: People v. Guajardo, 832 N.W.2d 409 (Mich. Ct. App. 2013).
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People v. Guajardo, 832 N.W.2d 409 (Mich. Ct. App. 2013). · cites it 5× “MCL 780.972(1). The statute provides, in relevant part, as follows: (1) An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be…”
People v. Moreno, 814 N.W.2d 624 (Mich. 2012). · cites it 4× “974, which explicitly clarify that certain other aspects of the common law relating to self-defense were not abrogated.”
People v. Stevens, 858 N.W.2d 98 (Mich. Ct. App. 2014). · cites it 3× “Under MCL 780.972(1): An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be with no duty to retreat if.”
People v. Dupree, 788 N.W.2d 399 (Mich. 2010). · cites it 2× “[20] See MCL 780.972. [21] People v. Conyer, 281 Mich.”
People v. Roper, 777 N.W.2d 483 (Mich. Ct. App. 2009). · cites it 2× “Instead of leaving the kitchen, punching Jones back, or requesting help from Morrow, defendant grabbed a knife and stabbed Jones with sufficient force to penetrate his neck by more than three inches.”
People v. Conyer, 762 N.W.2d 198 (Mich. Ct. App. 2008). · cites it 4× “*531 We conclude that the SDA in general, and MCL 780.972 in particular, apply prospectively only.”
People v. Bynum, 852 N.W.2d 570 (Mich. 2014). · cites it 2× “5 By enacting MCL 780.972, the Legislature codified the common-law requirement that for a killing to be justified by self-defense, a defendant must have both a subjectively honest belief and an objectively reasonable belief that the use of deadly force is necessary to prevent…”
People v. Richardson, 803 N.W.2d 302 (Mich. 2011). · cites it 2× “21c, which provides: (1) In cases in which [MCL 780.972] 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.”
People v. Orlewicz, 809 N.W.2d 194 (Mich. Ct. App. 2011). “MCL 780.972. A defendant’s history and psychological makeup may be relevant to explain the reasonableness of a defendant’s belief that he or she was in inescapable danger.”
People v. Campbell, 798 N.W.2d 514 (Mich. Ct. App. 2010). “The Conyer Court concluded that the statute in that case, MCL 780.972, which eliminated the duty to retreat in certain situations, should only be applied prospectively because it affected substantive rights and the Legislature had not manifested an intent that it be applied…”
People v. Goree, 819 N.W.2d 82 (Mich. Ct. App. 2012). “972, a criminal defendant may raise self-defense as follows: (1) An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be with no…”
People v. Wilder, 861 N.W.2d 645 (Mich. Ct. App. 2014). “MCL 780.972(l)(a). 6 Further, defendant did not argue the legal *563 defense of necessity, see People v Hubbard, 115 Mich App 73, 80 ; 320 NW2d 294 (1982); rather, her position was framed solely around the constitutional right to keep and bear arms.”
Show all 301 citing cases →
— Mich. Comp. Laws § 780.972(1) — 87 cases
People v. Guajardo, 832 N.W.2d 409 (Mich. Ct. App. 2013). “MCL 780.972(1). The statute provides, in relevant part, as follows: (1) An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be…”
People v. Stevens, 858 N.W.2d 98 (Mich. Ct. App. 2014). “Under MCL 780.972(1): An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be with no duty to retreat if.”
People v. Roper, 777 N.W.2d 483 (Mich. Ct. App. 2009). “Instead of leaving the kitchen, punching Jones back, or requesting help from Morrow, defendant grabbed a knife and stabbed Jones with sufficient force to penetrate his neck by more than three inches.”
People v. Conyer, 762 N.W.2d 198 (Mich. Ct. App. 2008). “*531 We conclude that the SDA in general, and MCL 780.972 in particular, apply prospectively only.”
Hinds v. Huss (E.D. Mich. 2023).
— Mich. Comp. Laws § 780.972(1)(a) — 101 cases
People v. Stevens, 858 N.W.2d 98 (Mich. Ct. App. 2014). “Under MCL 780.972(1): An individual who has not or is not engaged in the commission of a crime at the time he or she uses deadly force may use deadly force against another individual anywhere he or she has the legal right to be with no duty to retreat if.”
People of Michigan v. Theodore Paul Wafer (Mich. 2018).
Mitchell 948055 v. Vashaw (W.D. Mich. 2022).
People of Michigan v. Stanley John Garner (Mich. Ct. App. 2025).
20251114_C369555_53_369555.Opn.Pdf (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 780.972(2) — 47 cases
People v. Moreno, 814 N.W.2d 624 (Mich. 2012). “974, which explicitly clarify that certain other aspects of the common law relating to self-defense were not abrogated.”
People of Michigan v. Jason Dean Stout (Mich. Ct. App. 2025).
People of Michigan v. Micheline Nicole Leffew (Mich. Ct. App. 2020).
People of Michigan v. Eric Arlington Ogilvie (Mich. Ct. App. 2022).
People of Michigan v. Eric Arlington Ogilvie (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 780.972(l)(a) — 2 cases
People v. Roper, 777 N.W.2d 483 (Mich. Ct. App. 2009). “Instead of leaving the kitchen, punching Jones back, or requesting help from Morrow, defendant grabbed a knife and stabbed Jones with sufficient force to penetrate his neck by more than three inches.”
People v. Wilder, 861 N.W.2d 645 (Mich. Ct. App. 2014). “MCL 780.972(l)(a). 6 Further, defendant did not argue the legal *563 defense of necessity, see People v Hubbard, 115 Mich App 73, 80 ; 320 NW2d 294 (1982); rather, her position was framed solely around the constitutional right to keep and bear arms.”
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