North Carolina’s self-defense laws are often misunderstood. Many people believe that if they are in their own home and feel threatened, they have an absolute right to use deadly force. But a recent Court of Appeals decision in State v. Villarreal demonstrates an important limitation: if you are the aggressor who provoked the confrontation, the law will not protect you.
In February 2026, the Court of Appeals upheld a second-degree murder conviction against a defendant who shot and killed a man in his front yard. Despite the shooting occurring at the defendant’s own residence, the court found sufficient evidence that the defendant was the aggressor—which stripped away his self-defense claim entirely.
What Happened in State v. Villarreal
The case arose from a dispute over money. The victim, Ethan Troutman, received phone calls from someone at the defendant’s residence demanding a Netflix password. When Troutman refused because the caller owed him money, the situation escalated. The defendant eventually told Troutman to come to his residence to collect the debt.
When Troutman arrived, a confrontation developed in the front yard. Troutman pulled out a retractable metal baton after a dispute over a chain. Another person at the residence yelled that Troutman had a weapon. Within seconds, the defendant emerged onto the front porch with a gun. As Troutman turned to run away, the defendant fired a single shot, striking Troutman in the back. Troutman died from the wound.
Understanding North Carolina’s Aggressor Doctrine
North Carolina law generally permits the use of deadly force to prevent imminent death or great bodily harm under N.C. Gen. Stat. § 14-51.3. The law also creates a presumption of reasonable fear when someone unlawfully and forcibly enters your home under the Castle Doctrine (N.C. Gen. Stat. § 14-51.2). But these protections come with a critical exception.
Under N.C. Gen. Stat. § 14-51.4, self-defense is not available to someone who “initially provokes the use of force against himself or herself.” This is the aggressor doctrine. As the Court of Appeals explained, citing State v. Hicks, someone may be considered an aggressor if they “aggressively and willingly enter into a fight without legal excuse or provocation.” Importantly, you do not have to throw the first punch to be the aggressor. A person who did not start a fight may still be considered the aggressor if they “continue to pursue a fight that the other person is trying to leave.”
Why the Defendant Lost His Self-Defense Claim
Three facts proved fatal to Villarreal’s self-defense argument. First, multiple witnesses testified that the defendant invited Troutman to come to his residence. Second, witnesses testified that Troutman never actually raised or swung the baton at anyone. Third—and perhaps most damning—the defendant shot Troutman in the back as he was turning to flee.
The Court of Appeals noted that a victim being shot in the back supports an inference that the victim was trying to leave a fight, citing State v. Cannon. When someone is retreating, continuing to use force against them transforms you from defender into aggressor. At that point, the law no longer recognizes your right to self-defense.
Lessons for Those Facing Violent Crime Charges
This case illustrates several important principles for anyone facing homicide or assault charges in North Carolina. The Castle Doctrine and stand-your-ground laws have limits. Being on your own property does not give you unlimited authority to use deadly force. If you invite someone to a confrontation and then shoot them as they flee, you are likely to be convicted.
Self-defense cases are intensely fact-specific. The jury in Villarreal heard conflicting testimony from multiple witnesses. The court reviewed the evidence in the light most favorable to the State and found enough to support an aggressor instruction. Defense attorneys must anticipate how prosecutors will frame the evidence and prepare to counter the aggressor narrative.
Finally, what you do after a shooting matters. In this case, several people at the scene initially lied to police about what happened, claiming Troutman had entered the residence when he had not. This kind of cover-up rarely helps and often makes things worse.
Contact a North Carolina Criminal Defense Attorney
If you are facing murder, manslaughter, or assault charges and believe you acted in self-defense, the specific facts of your case will determine whether that defense is available to you. The Chetson Firm handles serious violent crime cases throughout North Carolina. Contact us to discuss your situation and your legal options.