Concealed Carry, Guide, Legal & Law, News, Self Defense

Which States Have a Duty to Retreat Before Using Deadly Force?

Self-defense laws in the United States differ from state to state, and one of the most misunderstood areas is the duty to retreat. This legal principle determines whether you must try to escape or avoid a confrontation before using deadly force — even if you’re facing danger.

While some states allow you to “stand your ground,” others legally require that you retreat, if it can be done safely, before using a firearm or deadly force. Understanding which rule applies in your state could mean the difference between a justified shooting and a criminal charge.


🧭 What Is the Duty to Retreat?

The duty to retreat means that before using deadly force, a person must make a reasonable effort to escape or avoid the threat if a safe path is available.

It doesn’t mean you have to run or put yourself in danger — but if a clear, safe way to withdraw exists, you must take it before resorting to deadly force.

By contrast, stand-your-ground laws remove that obligation, allowing a person to use deadly force if they reasonably believe it’s necessary to prevent death, serious injury, or certain violent felonies — even if escape was possible.


🗺️ States That Require a Duty to Retreat

As of 2025, the following states generally require retreat when safely possible, unless you’re inside your home (where the castle doctrine applies):

  • New York
  • New Jersey
  • Massachusetts
  • Maryland
  • Minnesota
  • Connecticut
  • Delaware
  • Maine
  • Hawaii
  • Nebraska – Active Legislation To Change To Stand Your Ground
  • Rhode Island

These are often referred to as duty-to-retreat states. Each has slightly different standards and exceptions — particularly regarding whether you’re in your home, workplace, or vehicle. In these jurisdictions, prosecutors and juries will scrutinize whether you could have safely disengaged or left the scene before using deadly force.


⚖️ States With Conditional or Limited Retreat Rules

A few states occupy a middle ground — they don’t impose a statutory duty to retreat, but courts may still consider whether retreat was possible when deciding if deadly force was reasonable.

Examples include:

  • California – No explicit duty to retreat, but prosecutors often argue that retreat was possible to challenge a self-defense claim.
  • Oregon & Washington – No formal duty, but the reasonableness of using deadly force can depend on whether retreat was an option.
  • Illinois & Iowa – Similar to California; retreat isn’t required by law, but it’s a factor in determining necessity.

🛡️ Stand-Your-Ground States

Most U.S. states — including Colorado, Texas, Florida, and Arizona — have no duty to retreat if you are lawfully present and not the initial aggressor.

Under these laws, you may use deadly force if you reasonably believe it’s necessary to prevent imminent death, serious bodily injury, or a violent felony. However, “no duty to retreat” does not mean “free license to shoot.” The threat must still be immediate, unavoidable, and proportionate.


🧩 How Duty to Retreat Affects Self-Defense Cases

When someone uses a firearm in self-defense, prosecutors and investigators will look at:

  • Was there a clear, safe route of escape?
  • Did the defender make any effort to de-escalate or withdraw?
  • Was the defender the initial aggressor?
  • Did the defender have a legal right to be there?
  • Was deadly force truly necessary, or was it a reaction born from anger or fear?

Even in stand-your-ground states, if you had a safe path to leave but chose to engage instead, it may still affect how your actions are judged in court or by a jury.


🧠 Key Takeaway

The difference between “stand your ground” and “duty to retreat” states is not about courage — it’s about legal strategy. If you carry a firearm, you need to understand exactly how your state defines self-defense, deadly force, and reasonableness.

When in doubt: if you can safely disengage, do it. Surviving the encounter is one thing — surviving the courtroom is another.


❓ Frequently Asked Questions

What happens if I use deadly force in a duty-to-retreat state without trying to escape?
You could face criminal charges, even if you believed you were defending yourself. The prosecution will argue that you had a reasonable opportunity to withdraw.

Do duty-to-retreat laws apply inside my home?
Usually not. Most states follow the castle doctrine, allowing you to defend yourself against intruders without a duty to retreat when inside your home.

Do I have to retreat if I’m at my business or workplace?
That depends on the state. Some extend castle doctrine protections to workplaces, while others do not. Always check your local laws.

If I’m in a car, do I have to retreat?
If you’re lawfully in your vehicle and cannot safely flee, deadly force may be justified. But if you can drive away safely, most duty-to-retreat states will expect you to do so.

Can I use a firearm in self-defense in a duty-to-retreat state?
Yes, but only as a last resort. You must reasonably believe deadly force is necessary and that no safe means of escape exists.



💼 Take the Next Step

  • 🛡️ Protect Yourself Legally — Compare coverage plans with our Self-Defense Insurance Guide to make sure you’re financially prepared for any legal aftermath.
  • 🎯 Get Certified — Enroll in our Colorado Concealed Carry Class to meet state training requirements and build confidence handling your firearm.
  • 🛒 Shop & Train — Visit our online shop for quality gear, holsters, and training aids, and check out our shooting drills to sharpen your defensive skills.

⚠️ Disclaimer

This article is for educational and informational purposes only and does not constitute legal advice. Laws vary by state and may change over time. Always consult a qualified attorney licensed in your state for guidance on self-defense and use-of-force laws.

Firearms Training, Guide, Legal & Law, News

Colorado Firearms Safety Course Eligibility Card – What to Know Before August 1, 2026

Starting August 1, 2026, Colorado will require residents to hold a Firearms Safety Course Eligibility Card (FSCEC) before purchasing certain types of firearms — primarily semi-automatic rifles, shotguns, and pistols.

This new requirement, part of Senate Bill 25-003, marks a major shift in Colorado firearm law and introduces a statewide system for training, background checks, and verification.


🔍 What Is the Firearms Safety Course Eligibility Card?

The Firearms Safety Course Eligibility Card (FSCEC) is essentially a permit-to-purchase system. It verifies that a buyer has:

  1. Completed an approved in-person firearms safety course, and
  2. Passed a background check through their county sheriff’s office.

The card acts as proof of competency and eligibility before a firearm purchase — but it does not replace Colorado’s standard purchase procedures. Buyers must still complete the federal NICS background check and comply with the three-day waiting period at the time of sale.


❓ Q&A: Common Questions About the New Law

When does the requirement take effect?

The law goes into effect on August 1, 2026. From that date forward, anyone buying a qualifying firearm in Colorado must first obtain a valid FSCEC.


Who issues the card?

Your county sheriff’s office will process applications, run background checks, and issue the FSCEC.
Each county may set its own procedures, application forms, and processing fees.


How does the process work?

According to the Colorado Division of Wildlife, which is assisting with system integration, the process will function as follows:

  1. Apply with your county sheriff.
    You’ll pay an application or processing fee to the sheriff’s office (or police department, depending on jurisdiction).
  2. The sheriff’s office conducts a background check to confirm eligibility.
  3. Once cleared, applicants complete an approved firearms safety course taught by a verified instructor certified to teach the Colorado Concealed Handgun Permit (CHP) course.
    You’ll pay a separate course fee directly to the instructor or firearms academy.
  4. After passing the written test, the instructor submits the student’s results into the state database.
  5. The sheriff finalizes the application and issues the Firearms Safety Course Eligibility Card.

Gun dealers will be able to verify a buyer’s active card status before completing the sale.


Do I still need a background check when I buy a gun?

Yes.
The FSCEC is an additional step, not a replacement. Every firearm buyer will still be required to:

  • Pass the federal NICS background check, and
  • Complete the three-day waiting period before taking possession.

How long is the card valid?

The FSCEC is valid for five years. After expiration, the cardholder must renew it and complete a refresher course.


Who can teach the required course?

Only verified instructors already authorized to teach the Colorado Concealed Handgun Course (CHP) will be permitted to teach the FSCEC-approved curriculum.

This ensures consistency, quality, and statewide training standards.


How long is the class?

There are two course formats:

  • 4-hour course – for applicants who already have a valid Hunter Education certificate
  • 12-hour course – for those without prior training

All instruction must be in-person. No online or hybrid classes will be accepted.


How much will it cost?

The total cost will vary depending on your location and chosen instructor:

  • Sheriff or Police Department Fee: Paid directly to your county sheriff or police department when submitting your FSCEC application. This covers background checks, processing, and card issuance.
  • Course Fee: Paid separately to your instructor or academy for the in-person firearms safety course. Costs vary depending on course length, location, and instructor credentials.

Applicants should plan for two separate payments — one to law enforcement for the card, and one to the instructor for the course.


Can instructors and dealers register now?

Not yet.
The state is still building the infrastructure to allow sheriffs, instructors, and dealers to register within a unified database. Once live, each group will need to create accounts in the new system.


Which firearms will require the FSCEC?

The Attorney General’s Office will finalize the specific definitions before the rollout, but current indications point to nearly all semi-automatic rifles, handguns, and shotguns being included.


What if I already own a semi-automatic firearm?

You can keep any firearm you legally owned before August 1, 2026.
The FSCEC applies only to new purchases made after that date.


Will out-of-state buyers be affected?

Yes. Colorado residents purchasing qualifying firearms from any FFL, in or out of state, must present a valid FSCEC at the time of purchase.


🧠 Key Takeaways

  • Effective August 1, 2026, Coloradans must hold a Firearms Safety Course Eligibility Card to buy semi-automatic firearms.
  • The FSCEC is issued by your county sheriff after passing a background check and completing an in-person course.
  • You’ll make two payments — one to the sheriff or police department for the application and one to your instructor or academy for the class.
  • Only verified CHP instructors may teach the FSCEC course.
  • The card is valid for five years and may be revoked for disqualifying offenses.
  • Buyers must still pass the federal background check and three-day waiting period when purchasing a firearm.

✅ What You Can Do Now

  • Follow your county sheriff’s website for FSCEC registration updates.
  • Plan ahead — demand for classes will likely surge before the 2026 deadline.
  • Take your CHP class now to prepare and get verified instruction early.
  • Budget for both training and application fees.
  • Stay informed through Concealed Carry Classes of Denver for FSCEC announcements and approved class schedules.

📍 Sign Up for a Colorado Concealed Handgun Course

If you’re ready to carry a concealed firearm legally in Colorado, you must complete an approved Colorado Concealed Handgun Permit (CHP) course.

Our CHP classes meet all state requirements and include law, safety, and live-fire qualification. Perfect for both new and experienced firearm owners.

Class Locations: Denver & Thornton
Duration: 8 hours
Includes: Classroom instruction, legal overview, and live-fire qualification
Enroll here: Colorado Concealed Handgun Course


🔒 Sign Up for the Colorado Firearms Safety Course (FSCEC Requirement)

Beginning August 1, 2026, all Coloradans purchasing a semi-automatic firearm will need a Firearms Safety Course Eligibility Card (FSCEC).

Our state-approved course meets all training requirements and is taught by verified CHP instructors authorized to conduct FSCEC training.

Class Locations: Denver & Thornton
Duration: 4 or 12 hours (depending on prior hunter safety)
Includes: In-person classroom instruction, written test, and state database registration
Enroll here: Colorado Firearms Safety Course



⚠️ Disclaimer

This article is for informational purposes only and does not constitute legal advice. Details may change before August 1, 2026. Always verify requirements with your county sheriff or the Colorado Bureau of Investigation (CBI).

Legal & Law, News

Portland Cannabis Store Employee Acquitted in Double-Homicide Case After Robbery Attempt


A Portland cannabis store employee, Jason Steiner, has been found not guilty on all charges in connection with a double homicide that occurred during an attempted robbery at La Mota, a cannabis dispensary in North Portland.

🎥 Watch the full coverage here:
YouTube – Portland Cannabis Store Shooting


The Incident

According to police and court records, three men entered the La Mota cannabis dispensary in what appeared to be an armed robbery. Two of them were armed with handguns and pointed them directly at the only employee working that night — Jason Steiner.

Steiner was held at gunpoint and forced outside the store while the armed suspects remained inside to continue the robbery. Once outside, Steiner retrieved his firearm from his backpack, moved to a nearby window, and fired 13 rounds through the glass at the suspects inside the store.

Two of the robbers were struck and killed. The third fled.

Investigators later confirmed that Steiner was a lawful employee and had every right to be on the property. Prosecutors, however, charged him with two counts of murder, arguing that because he was outside when he fired, he was no longer in “imminent danger.”

After a full trial and extensive review of surveillance footage, ballistics, and testimony, a jury acquitted Steiner on all counts, concluding that his actions were justified under Oregon’s self-defense statutes.


My Professional Take

As a firearms instructor and self-defense law educator, I believe the jury got this case exactly right — and it’s outrageous that the DA’s office ever filed these charges.

Jason Steiner was working alone when two armed men entered his store, pointed guns at him, and forced him outside. That experience doesn’t suddenly become “safe” just because he ended up on the other side of a wall or door. The threat was still unfolding, and any reasonable person in his position would have feared for their life.

He didn’t chase anyone down. He didn’t act out of vengeance. He acted out of fear and survival, responding to an immediate and violent situation created entirely by the suspects.

The idea that he “should have just run away” is completely detached from reality. Oregon law doesn’t require that. There’s no duty to retreat when you’re lawfully present and face a deadly threat (State v. Charles, 1982; State v. Sandoval, 2007*).

The DA tried to criminalize a man for surviving an armed robbery — and that’s exactly what’s wrong with how self-defense is being treated in some jurisdictions today.

Steiner was a lawful employee, forced at gunpoint out of his own workplace, and still facing a threat from armed criminals. He had every right to defend himself, and the jury agreed.

This case is a textbook example of how self-defense can be legally, morally, and tactically justified — even when the defender is outside the building. He didn’t run — he lived.


The Civil Side — What Happens Next

Even though Jason Steiner was rightfully acquitted, don’t be surprised if his name — and the dispensary’s — show up in a civil lawsuit next.

That’s how this system works. When the criminal case fails, civil attorneys often circle back to see if there’s still money to be made. They’ll likely go after everyone involved — Steiner, La Mota, maybe even the property owner or their insurance carrier — under a wrongful death or negligence claim.

It doesn’t mean the case has merit. It just means that in civil court, the standard of proof is lower — “more likely than not” instead of “beyond a reasonable doubt.”
So even when someone is clearly justified, they can still get dragged through years of litigation and tens of thousands of dollars in legal fees defending themselves again.

That’s why I always stress to my students and guards:
Get self-defense insurance.

Without it, one justified act can bankrupt you in legal fees alone. Even when you do everything right — lawfully, morally, and tactically — you can still end up defending your life a second time in civil court.

If that happens here, Jason Steiner will probably be listed right alongside the dispensary, and they’ll both have to fight another battle — not for freedom this time, but for financial survival.


Self-Defense Law in Oregon

Oregon’s justification statutes outline when force — including deadly force — may be lawfully used:

  • ORS 161.209 allows the use of physical force when a person reasonably believes it is necessary to defend themselves or another from the use or imminent use of unlawful force.
  • ORS 161.219 allows deadly physical force when the defender reasonably believes the aggressor is committing or attempting to commit a felony involving force, or is about to use deadly force.

In plain terms: Oregon law centers on reasonableness and necessity, not on retreating or hesitation in the face of imminent danger.


No Duty to Retreat Under Oregon Law

Unlike some states, Oregon does not impose a legal duty to retreat before using deadly force in self-defense. As long as a person is lawfully present and reasonably believes deadly force is necessary to stop an imminent threat of death or serious bodily injury, they are justified in standing their ground.

This principle is confirmed by both statute and case law:

State v. Charles, 293 Or. 273 (1982) — The Oregon Supreme Court held that a person claiming self-defense “is not required to retreat or to consider whether he could safely retreat” before using force.
(647 P.2d 897 (Or. 1982))

State v. Sandoval, 342 Or. 506 (2007) — The court reaffirmed that nothing in ORS 161.219 “suggests that persons who reasonably believe another person is about to use deadly physical force against them must calculate whether it is possible to retreat before using deadly physical force in self-defense.”
(174 P.3d 272 (Or. 2007))

Together, these rulings make it clear: Oregon law protects the right to stand your ground if you are lawfully present and faced with an imminent, unlawful threat.


My Perspective

In Jason Steiner’s case, this legal principle couldn’t be more relevant. He was lawfully inside and outside his workplace during a violent felony, and the threat never stopped being real. Oregon law did not require him to flee or hide — he had every right to defend himself.

The jury recognized that. They understood that self-defense is not murder when the threat is real, immediate, and unlawful. Justice was served.


Lessons for Armed Citizens & Business Owners

  • Have a plan. Armed robberies unfold in seconds — not minutes. Training and situational awareness save lives.
  • Know your state laws. Whether you’re in Oregon, Colorado, or Texas, the same principles apply: reasonableness, necessity, and lawful presence.
  • Don’t provoke. Don’t hesitate. If you are lawfully present and face a deadly threat, you have the right — and the duty — to protect yourself and others.

Final Thoughts

This case serves as another real-world reminder that self-defense is not a crime when the threat is real and the defender is lawful.

For every CCW holder, business owner, and armed professional, this verdict reinforces one truth:
You have the right to go home safe.



Call to Action

➡️ Sign up for a Colorado Concealed Carry Class – Learn the laws, tactics, and judgment skills needed to protect yourself legally and responsibly.
➡️ Compare Self-Defense Insurance – Don’t face a courtroom alone. Visit our Self-Defense Insurance Comparison Chart to find the best coverage.


Disclaimer

This article reflects the professional opinion of Mark Schneider, firearms instructor and Force Science Analyst.
It is not legal advice. Always consult an attorney for specific legal guidance.