Each State/Commonwealth has it's own laws on self-defense. In Michigan, the last case of which I am aware that discusses self-defense, is People v. Marcel Riddle. I haven't found anything about a heightened duty/responsibility due to training in martial arts to retreat twice.
Here is an excerpt from that case (467 Mich 116 (2002):
" The prosecution contends that Michigan law generally imposes a Āduty to retreatĀ upon a person who would exercise deadly force in self-defense, and that the so-called Ācastle doctrineĀĀproviding an exception to this duty to retreat when a person is attacked within his dwellingĀdoes not extend to the area outside the dwelling. Defendant, on the other hand, contends that the castle doctrine should be extended to the curtilage and that he was not required to retreat when he was assaulted in his backyard.
Because MichiganĀs case law has become somewhat confused with respect to the concepts of retreat and the castle doctrine, we take this opportunity to clarify these principles as they apply to a claim of self-defense. We reaffirm today the following, according to the common-law principles that existed in Michigan when our murder statute was codified.
As a general rule, the killing of another person in selfdefense by one who is free from fault is justifiable homicide if, under all the circumstances, he honestly and reasonably believes that he is in imminent danger of death or great bodily harm and that it is necessary for him to exercise deadly force.3 The necessity element of self-defense normally requires that the actor try to avoid the use of deadly force if he can safely and reasonably do so, for example by applying nondeadly force or by utilizing an obvious and safe avenue of retreat.4
There are, however, three intertwined concepts that provide further guidance in applying this general rule in certain fact-specific situations. First, a person is never required to retreat from a sudden, fierce, and violent attack;nor is he required to retreat from an attacker who he reasonably believes is about to use a deadly weapon.5 In these circumstances, as long as he honestly and reasonably believes that it is necessary to exercise deadly force in self-defense, the actorĀs failure to retreat is never a consideration when determining if the necessity element of self-defense is satisfied; instead, he may stand his ground and meet force with force.6 That is, where it is uncontested that the defendant was the victim of a sudden and violent attack, the Court should not instruct the jury to consider whether retreat was safe, reasonable, or even possible,because, in such circumstances, the law does not require that the defendant engage in such considerations.7
Second, Michigan law imposes an affirmative obligation to retreat upon a nonaggressor8 only in one narrow set of circumstances: A participant in voluntary mutual combat will not be justified in taking the life of another until he is deemed to have retreated as far as safely possible.9 One who is involved in a physical altercation in which he is a willing participantĀreferred to at common law as a Āsudden affrayĀ or a Āchance medleyĀĀis required to take advantage of any reasonable and safe avenue of retreat before using deadly force against his adversary, should the altercation escalate
into a deadly encounter.
Third, regardless of the circumstances, one who is attacked in his dwelling is never required to retreat where it is otherwise necessary to exercise deadly force in selfdefense. When a person is in his Ācastle,Ā there is no safer place to retreat; the obligation to retreat that would otherwise exist in such circumstances is no longer present, and the homicide will be deemed justifiable. This is true even where one is a voluntary participant in mutual combat."
Miles
