Duty to Retreat from One's Home, When Attacked by a Cohabitant?

Even states that generally impose a "duty to retreat" before using deadly self-defense exclude self-defense in the home -- but what if the self-defense is against a cohabitant?

|The Volokh Conspiracy |

Wyoming is one of the few Western states that recognizes a "duty to retreat"—i.e., provides that people lose their rights to deadly self-defense when they can avoid the threat to life or limb with perfect safety by fleeing. But there's an exception to the "duty to retreat" called the "castle doctrine": Even in duty-to-retreat states, people need not retreat if they are assaulted in their own homes. (All this assumes, by the way, defenders who aren't at fault in the original attack, and are where they have a right to be.)

Now some duty-to-retreat states recognize an exception to the exception: When people are attacked in their own homes by cohabitants who share the same homes, the castle doctrine doesn't apply, and the duty to retreat kicks back in. In last week's Widdison v. State, the Wyoming Supreme Court held that the castle doctrine does apply (and thus the duty to retreat does not apply) in such a situation:

The majority of jurisdictions that have considered the issue conclude that a cohabitant does not have a duty to retreat in his own home when, through no fault of his own, he is assailed by another cohabitant. Linda A. Sharp, Homicide: duty to retreat where assailant and assailed share the same living quarters, 67 A.L.R.5th 637, § 2(a) (1999 & 2017 Supp.) (fourteen jurisdictions hold cohabitant has no duty to retreat; seven jurisdictions require cohabitant to retreat, one of which (Florida) has since abandoned that rule). These courts reason that it would be illogical to require retreat when one is attacked in one's own home by a cohabitant, but not when attacked by a stranger. "The danger posed and the sanctuary of the dwelling is the same regardless of the status of the attacker." …

We require reasonable retreat in self-defense outside the home because the law presumes that there is somewhere safer to go-home. But self-defense in the home is based on the premise that the home is "a place critical for the protection of the family." Requiring retreat from the home before acting in self-defense would require one to leave one's safest place…. "[A] man assailed in his own dwelling … is under no duty to take to the fields and the highways, a fugitive from his own home…. Flight is for sanctuary and shelter, and shelter, if not sanctuary, is in the home." …

In contrast, a minority of jurisdictions distinguish encounters between cohabitants and intruders and require retreat when one is attacked by a cohabitant. Those courts focus on the "entitlement of both combatants to occupy the house and the fact that they usually are related, and reason that the parties have some obligation to attempt to defuse the situation."

We conclude that the majority rule is the better-reasoned approach. When a person is attacked within her dwelling, the right to defend herself and the privilege of non-retreat should not depend upon the identity of the attacker. "Further, forcing a resident to retreat from the home is at odds with the historical notion of the home as a place critical for the protection of the family."

In addition, applying the castle doctrine to cohabitants will better protect victims of domestic violence. As the Florida Supreme Court recognized when it abandoned the minority view, "placing a duty to retreat from the home on the defendant may serve to legitimize the common myth [that victims of domestic violence are free to leave the battering relationship any time they wish to do so, and that abuse could not have been so bad because otherwise she would have left] and allow prosecutors to capitalize upon it."

The defendant in this case was a woman who stabbed her uncle (Jones), with whom she was living; apparently both were quite drunk at the time:

Mr. Jones did not have a clear recollection of the events leading up to the incident. He did testify that when their argument began to escalate, he told Ms. Widdison that she had to leave his home.

Ms. Widdison testified that the conflict arose because Mr. Jones insisted that she give him oral sex in exchange for staying at his home. She stated that he threatened her with a knife and pinned her to the ground, and that she wrestled the knife away from him. She recalled nothing about the stabbing or a second knife.

Ms. Widdison also testified that she was afraid Mr. Jones was going to kill her and that he had threatened her with weapons before. The defense presented two additional witnesses. Darcey Fulmer, another of Mr. Jones' nieces, testified that Mr. Jones had a propensity for violence and inappropriate sexual solicitation and touching, especially when he was drunk. The second witness, Mr. Jones' nephew, Yancey Norton, also testified regarding Mr. Jones' reputation for violence and for making unwanted sexual advances. Mr. Norton recounted an incident in which Mr. Jones had locked him and Ms. Widdison in the basement and threatened to kill them with a gun he was holding.

The district court interrupted the testimony and prohibited the defense from presenting that or other testimony regarding specific instances of Mr. Jones' conduct. The defense rested without calling two additional family members who had been listed as witnesses to testify regarding Mr. Jones' reputation and propensity for violence….

The court [also] refused Ms. Widdison's proposed [jury] instruction on the "castle doctrine." … The jury returned guilty verdicts on both counts, and the district court sentenced Ms. Widdison to concurrent sentences of twenty-five years on the attempted second-degree murder charge and eight to ten years on the aggravated assault charge.

There was some dispute about whether Widdison was actually living at the house, but the court pointed out that there was enough evidence that the jury should have been instructed to resolved the dispute:

The State argues that Ms. Widdison was legally a trespasser because Mr. Jones had asked her to leave prior to the stabbing and that based upon the evidence, the district court's conclusion that Mr. Jones' home [because "You don't ask somebody to leave their own residence if it's their residence, if it's their house"] was not Ms. Widdison's residence was a reasonable one. However, even the district court recognized that the determination needed to be made in the face of conflicting evidence. The court remarked, "The testimony seems to be conflicting on that category and so I made a judgment call in that respect." Unfortunately, it was not the district court's job to make that call.


NEXT: Armed School Resource Officer Stayed Safely Outside School While Mass Killing Was Underway

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  1. “Wyoming is one of the few Western states that recognizes a “duty to retreat” — i.e., provides that people lose their rights to deadly self-defense when they can avoid the threat to life or limb with perfect safety”

    What an absurd idea. There is no such thing as perfect safety. Standing perfectly still alone in a locked room doing nothing but breathing is not “perfectly” safe.

    1. And if the situation arises you’re welcome to make that argument to the jury. If you’re on trial for shooting a black guy, I’d imagine that this argument would have a pretty good chance of success.

      1. Why are you a racist?

        1. This isn’t about his racism, it’s about his anti-American bigotry.

      2. Harvey, I don’t get your comment. I don’t see where Martinned said that it was a *good* thing that one would be more likely to succeed with this defense if the victim were black. That would indeed be racist.

        If Martinned had said that, in many parts of the country, a black or hispanic male is much more likely to be pulled over for minor traffic violations; would he be racists for making a factual claim.

        It’s possible that you’re confused about what amounts to racism. (Hint: it’s the underlying behavior/action, not the assertion that the behavior does–or does not–exist.)

        1. As I mentioned, it’s Martinned being a bigot, not a racist. You know, one of those evil clingers Arthur is always railing against.

        2. But you don’t seem to have understood Martinned’s claim: it was that you’d be fine if you shot a clearly innocent black man in your house. He’s probably also sticking bigotry on the other end, where he’s assuming the shooter is white.

    2. My general problem with the Duty to Retreat is that the prosecution can use perfect 20/20 hindsight and extensive research to identify escape routes that were not visible to the defendant, focusing completely at the time on the danger to their life, thus negating the defense of self-defense.

      1. Sure, and the defendant is perfectly free to argue to the jury that the prosecution’s theory is implausible because the escape route in question was not apparent to him at the time.

      2. Justice Holmes: “Detached reflection cannot be demanded in the presence of an uplifted knife.”

        1. But that is precisely what is demanded of defendants in many cases where the Retreat Doctrine is utilized to negate self-defense – detached reflection. “I didn’t see the avenue of retreat provided by the prosecution, in the pressure of the encounter” is just not a valid defense in many jurisdictions. The question is not whether the defendant saw that avenue of retreat, but rather whether there was one, and, maybe, if they are lucky, whether they logically could possibly have seen it.

          1. What must be remembered is that prosecutors don’t operate in a vacuum. At some level, there are almost always politics involved. Self defense cases are sometimes politically unpopular, and can be easy wins for the prosecution. All they need to do to win the case in many cases is negate just one element of the self-defense claim, since, to get to the question of self-defense in the first place essentially requires that the prima face case for the underlying crime be fairly strong. When deadly force is used, you may have have both the body and a slam dunk case of homicide. All that stands between the defendant and prison is his defense of self defense. Sure, he killed the “victim”, but the “victim” shot first. Etc. One of the big reasons that a majority of states have abrogated the Retreat Doctrine is the widespread view that many prosecutors have utilized it to convict people who engaged in justified self-defense. In other words, if a number of prosecutors hadn’t abused it in the past, in order to get either easy or politically popular convictions, it would still be the law of the land, instead of, now, a minority reminent of the common law. (My guess is that Wyoming hasn’t bothered to abrogate it, because a Most of its citizens probably effectively ignore jury instructions that try to impose it, due to their Wild West concept of justice).

            1. Sounds like a great argument for not having elected prosecutors…

              Also, I’m not sure why you’re so reluctant to send people to jail when they admittedly killed someone. What’s so great about, as you put it, Wild West justice?

              1. “Also, I’m not sure why you’re so reluctant to send people to jail when they admittedly killed someone.”

                So you believe that there should be NO right to self defense under any conditions?

            2. The Wyoming-style”Wild West concept of justice” is an apt compliment to substandard educational and economic performance (and to the Wyoming end of bright flight).

              1. The Wyoming-style”Wild West concept of justice” is an apt complement to substandard educational and economic performance (and to the Wyoming end of bright flight).

  2. Under the ancien regime, a married person would have a special duty to preserve their spouse’s life even if they got angry, and this would certainly justify a duty to retreat. If you are getting into a fight with your spouse and the fight is getting out of control, leaving is often a wise think to do, and under the old, paternalistic regime, the law could certainly require it.

    The idea that the people one lives with are mere cohabitants indistinguishable from strangers would have been inconceivable to any traditional human society, except perhaps one so small and isolated that no concept of strangers existed. And for good reason.

    There is no logical reason that a society should survive. Many haven’t. The reasons for survival are not always logically obvious. And this is perhaps a paradigmatic example of Justice Holmes dictum that a page of experience is worth a thousand pages of logic. A society where upstart judges throw out practices that have promoted survival and peaceful coexistence for generations just because hey violate their strange aesthetic sense of logic is not necessarily a good survival candidate.

    I would nominate the judges here for the Darwin Awards. Let spouses stand their ground, shoot each other up, and die dead right.

    1. Obviously you didn’t read the article carefully. The case described involved a woman living with her uncle, not spouses.

      The trial judge decided that the castle doctrine didn’t apply because the Uncle claimed he ordered his niece to leave, so it wasn’t her residence.

      The appellate court ruled that there was a factual dispute about the revocation of the niece’s permission to live in her uncle’s house and that the issue of her being kicked out or not should have been given to the jury to rule on rather than the judge ruling on it.

    2. The idea that the people one lives with are mere cohabitants indistinguishable from strangers would have been inconceivable to any traditional human society, except perhaps one so small and isolated that no concept of strangers existed.

      This is very, very much untrue. The law of hospitality often meant you had strangers living with your for weeks. The Romans ‘hosted’ the Visgoths for quite a while. And the tradition of quartering soldiers was not a specifically British one.

      In fact, the idea of one’s home including the right to exclude is the more recent invention.

      1. Due to increasing wealth in society, I think. The law of hospitality was because you could have somebody come to your door asking for shelter, and refusing it would be a death sentence for them.

        It was a much bigger deal than it generally is today.

  3. Here, the logic of a duty to retreat for fights with spouses is perceivable to anyone with common sense or understanding of human nature and foibles, including a tendency to get uncontrollably angry sometimes, and a society’s need for its members to survive this and live, not die throwing logical syllogisms at each other along with the knives and bullets.

    What’s going on here isn’t that customary law in this area has no logic behind it. It makes eminent sense. The reason the judges can’t see reason here is that they are blind to it.

    1. This isn’t a spouses case, it’s an uncle/niece case with the nice living with her uncle.

      1. But even if it was a spousal situation, ReaderY’s logic doesn’t work. In a fight, which spouse has the duty to retreat? When one spouse doesn’t, why is it suddenly the other’s obligation to be dispassionate and perfectly aware?

        Yes, we should all forgive each other and be tolerant of foibles. Being physically attacked to the point that you fear for your life (a question for the jury about your credibility) is no longer a “foible”.

        1. “In a fight, which spouse has the duty to retreat?”

          Isn’t that obvious? In a state where the right to self defense is held hostage to a duty to retreat, in a domestic violence situation, it would always be the victim, the non-aggressor who has the duty to retreat.

  4. Matthew:

    Yes, but the principles ReaderY raises seem equally applicable to both spouses and blood relatives. In a fight between two people living in the same house, it does seem best to set a rule that they must retreat, rather than treat it as a cage match.

    1. So what you are saying is that we shouldn’t listen to women, right?

      1. Where does that come from?

        1. It comes from the cold, socially inept, disaffected heart of the conservative.

      2. Not at all, Cathy Newman.

        I think he’s suggesting that in close relationships, a willingness to put down metaphorical arms and cool down a bit before trying to resolve every single dispute is a good thing. If you try to win every single argument with your spouse, soon you will have no spouse.

        But of course, comparing run-of-the-mill verbal spats, even quite heated ones, with instance of violence or true threat of it is to make a significant mistake. Normal people do not escalate disagreements into serious violence. And you really should focus on that — not on egregiously mischaracterizing his argument.

        1. Who is Cathy Newman?

          1. Cathy Newman is the BBC interviewer who recently made waves for interviewing Jordan Peterson and at nearly every opportunity responding to his comments with, “So you’re saying that…” followed by a gross mischaracterization of his argument.

        2. They don’t?

          Alexander Hamilton, to give one example of many famous people, was crazy?

          History and contemporary sociology say that many, although by no means all, ordinary people who function effectively in society most of the time do indeed sometimes have violent spats. Many spousal murders are by people who generally function well in society and aren’t likely to commit other crimes. It may not seem logical that this should be so. But then again, it also isn’t consistent with our sense of how things should logically be that disease and natural disasters exist. Historically, society has found it more valuable to try to keep these these tendencies capped and prevent them from getting people killed than using them as occasions for more self-possessed people to chortle over their genetic fortune. More easily-enraged people might be better at protecting the community from predators, for example, and may have other valuable traits, although perhaps not as easily perceptible in current social conditions.

          It is often better to accept a human weakness and work to limit its consequences than to try to root it out and thereby exacerbate its damage. The opioid crisis, sexual issues, and other matters are also areas where this comes up.

          1. Okay — in modern times, normal people’s disagreements do not escalate into serious violence. Hamilton’s dueling culture does not exist today. The cases where disagreements escalate into serious violence are rare.

            When serious violence does issue, it tends not to be from run-of-the-mill disagreements where disengagement, reflection, and rapprochement are in order. There’s a categorical difference between the runup to serious potential for violence, and the normal heated argument that can be resolved once both sides cool down. Serious threat of violence, rather, arises in cases like domestic violence that have not much to do with some instant disagreement, that therefore can’t necessarily be resolved by both parties cooling down. In such cases, duty to retreat may well mean the woman must leave the house for the street — which hardly seems the right thing either morally or practically.

            1. I am not saying that a majority of people do it. Only a small minority of people commit homicides. I not suggesting homicide is normal. The universe of people to look at is the sort of people who commit homicides, assualts causing serious injuries, etc. What I am saying is that of people who commit homicides, this situation is common enough that addressing it could have a substantial harm reduction impact.

              The concept of harm reduction is today generally associated with liberals, and used for things like supervised drug-injection sites, decriminalizing prostitution, easing up on immigration enforcement, and other current liberal causes. But it’s a traditional idea that appears in many places in the common law, including this.

              It may be wrong. The harms reduced might not outweigh the harms caused by deviating from what might be perceived as strict justice or fairness. But it’s completely rational.

              What I’m objecting to is judges declaring it irrational because they disagree with it on ideological grounds. I often object to liberal judges declaring conservative policies irrational just because they disagree with them. Here I’m objecting to conservative judges declaring liberal policies irrational.

    2. Sorry, I have a general issue with the idea of a duty to retreat, as you might have noticed if you bothered to read my first comment on this thread.

      A duty to retreat when it is perfectly safe to do so, is either insane or a nullity, because in my opinion, it can never be “perfectly” safe to retreat from a violent attacker. And even reasonably safe to retreat will be exceedingly rare.

      1. You’re right: arm the teachers!

        1. Arm teachers? What are you, a commie gun grabber?

          Arm everyone!

        2. I have the right to arm bears. 🙂

  5. Wait, the home where you’re being attacked is “one’s safest place”?

    I don’t get this logic at all.

    1. Maybe not the immediate safest place at that precise moment, but if the choice is staying or being rendered homeless, as opposed to staying or going home?

      1. How about going to the police station?

        1. And living there?

          When attacked someplace other than your home, retreat does not deprive you of a home. When attacked in your home, it does.

          It’s balancing an acute threat against a lesser persistent threat.

          I must say though that in the case given, I’m not impressed with the castle doctrine claim.

          1. Sorry, my (perhaps foolish) assumption was that if you go to the police station and tell them that there is an armed attacker in your house, that the police will do something about that.

            1. And, where the armed attacker’s right to be in the house is equal or, as in this case, superior to your own?

              1. If the armed attacker has a right to be in my house, that doesn’t mean that they have a right to attack me with arms in my house. So I’m not sure why that would get in the way of the police’s ability to restore me to the peaceful enjoyment of my house.

                1. In the immediate case, they were scarcely going to eject the home owner in favor of his niece.

                  To be sure, she could have fled the house. Should have fled the house already, if her account of life there is accurate!

                  But I don’t see any scenario where she ends up living in the uncle’s house, with the uncle removed. He was the one with the right to live in the house, owning it, and she was there on his sufferance.

                  In the more general case where two people have an equal claim to a house? Then it gets complicated.

                  But I’m just pointing out why a house where you’re attacked might be, in some sense, your “safe” place.

                  1. Not sure if the niece is old enough to live on her own, but you don’t think the uncle might get arrested for assaulting his niece with a knife?

                    1. No, she’s clearly an adult.

                      And, yes, the uncle could get arrested for assault, if there was evidence. As it is, she got convicted of assault for attacking him. The claim that he’d attacked her was part of her defense in the trial.

                    2. Yes, because she didn’t retreat. That’s the whole point of this conversation.

                    3. Possibly because she attacked, and needed an alibi. Attackers almost by definition don’t retreat.

                      I think it’s possible to go too far in assuming her defense in this case was honest; She’s got a rap sheet, and it includes a prior conviction from 2012 for aggravated assault resulting in severe bodily injury.

                    4. “Not sure if the niece is old enough to live on her own, but you don’t think the uncle might get arrested for assaulting his niece with a knife?”

                      Even if he gets arrested and jailed:

                      The Uncle looses his job and defaults on his mortgage.

                      When the bank forecloses, the niece has not standing to contest the foreclosure or file for bankruptcy on her uncle’s behalf.

                      The point is, if the niece retreats and goes to the cops, she ends up homeless no matter what else happens.

                2. When seconds count, the police are only minutes away.

            2. Depends, you might be served by the Broward County sheriff’s office. The deputies there are too scared to do something.

              1. One man for whatever reason did not react as he has been trained to in a moment of crisis and now the entire Broward’s County Sheriff’s Department are cowards?

                1. More is coming out. He apparently didn’t cooperate with the earlier investigation of That Clown, before he started killing people.

        2. The Supreme Court has repeatedly ruled that the police have no obligation to protect you.

  6. Isn’t this more a “duty not to return” than a “duty to retreat” case, in as much as the alleged threat was long established at the time of the actual altercation?

    In any event, I’m generally disposed to regard as illegitimate trials where the defense is barred from calling its chosen witnesses. Even if the court thought the castle doctrine question wasn’t relevant, they would have shored up the claimed threat.

  7. Does conservatism generate fans of shoot-’em-up laws (and gun nuts in general), or merely attract them?

    Similarly, will support for shoot-’em-up laws cause the decline of the Republican-conservative electoral coalition, or will it be vice versa?

    Either way, carry on (until then), clingers.

    1. As far as I can tell these laws mostly seem to get minorities killed. And given that minorities disproportionately vote Democrat, I’m not sure where the decline of conservatism is supposed to come from.

      1. The decline of conservatism will come from continuing improvement in America’s electorate and society (less backward, less rural, bigoted, less white, less religious).

        Also, a preference for reason, tolerance, science, education, and modernity is superior to a preference for backwardness, intolerance, ignorance, dogma, and superstition.

        I expect the trajectory of America’s progress — toward the preferences of the liberal-libertarian alliance, opposing the preferences of conservatives — we have observed for a half-century or more to continue.

        1. In my experience, it is better to hope for the best and prepare for the worst. If the country can vote for Trump, there’s no telling what else they might do.

          1. I noted to Bob from Ohio several days ago (when he lamented not having an Ignore function under Reason), that he illustrated the repubs’ efforts to addressing issues.


            Build a wall.
            Have a gun.

            And cut funding…

            So, thank you M’ed for supporting my observation.

            1. “he illustrated the repubs’ efforts to addressing issues”

              I have no problem addressing issues, I do have a problem reading tedious diatribes from a certain anti-religion bigot. You have to scroll down and inadvertently read his poison.

              That particular bigot was using the clingers line before 2016 too. How did that work out?

              1. You keep focusing on the 2016 presidential election, Bob.

                I will concentrate on a half-century of liberal-libertarian progress at the expense of conservatives’ aspirations, and the prospect of another half-century of similar progress despite the efforts and preferences of clingers.

              2. I suggest using Greason, a plug-in for chrome that improves the Reason reading experience. The best feature is filtering based on poster.

              3. Granted, I understand finding the posts tedious, but what is wrong with anti-religious bigotry? You say it it’s bad. When you aren’t religious (for them it would be hypocracy or baseless to judge), and you are at, don’t we have a duty to not tolerate points of view which lack evidence/proof. Not all bigotry is bad. I.e. Intolerance of Nazis…. And religion is by definition belief in that which lacks supportive evidence. I shouldn’t have to argue for rationality over irrationality on reason, but can you argue against it? It’s wrong to teach children to believe in the baseless. Religion is harmful and hurts people’s ability to think rationally and blinds them to this inability. So sure, complain about the repetition, but not about Intolerance for poor reasoning.

    2. Is there a reason that you perpetually comment with ad hominem and usually irrelevant attacks? Is it just that you like to provoke trolls.

      Carry on troll.

      1. “Is there a reason that you perpetually comment with ad hominem and usually irrelevant attacks?”

        If people ignored him, he’d eventually comment less.

        We re not fish, no need to always take the bait.

  8. Does conservatism generate fans of shoot-’em-up laws (and gun nuts in general), or merely attract them?

    Similarly, will support for shoot-’em-up laws cause the decline of the Republican-conservative electoral coalition, or will it be vice versa?

    Either way, carry on (until then), clingers.

    1. Considering that neither of the combatants were using a gun…

      1. There you go again, introducing facts and reason into a political rant.

    2. Poor Kirkland (assuming he is not a Russian troll) what a sad life, so much frustration and so much time to post. A real, full time, job might improve his outlook on life.

        1. Yeah, the real problem at the Volokh Conspiracy and is too many liberal and libertarian comments and not enough movement conservatism in all of its backward, intolerant glory.

          Try to have some fun, clingers.

          1. Wonder if continuous repeating of “carry on clingers,” indicates a deep belief (perhaps subconsciously) that “clingers” continuing to cling is the last best hope for the Americans?

          2. If the problem is too many libertarian comments then you clearly are not the problem. You do have some comments that are libertarian however. I actually agree with the ones concerning ending the drug war, civil asset forfeiture, and holding government actors responsible for their screwups.

            It’s really too bad that you have adopted the troll mentality over the past few years. I miss the Arthur Kirkland posts of old that had some substance even though I disagreed with many of them. Any chance of that Arthur Kirkland making a comeback and letting the troll have some time off?

            1. Do you similarly, or ever, object to the incessant liberal- and moderate-bashing, the barely veiled bigotry, the ridiculous faux libertarianism, and similar comments that outnumber mine 10 to 1?

    3. What’s a “shoot-’em-up law,?” You think we live in some kind of kind society, where an intruder is just there to take what he needs to feed his starving baby, and has every right to, and would never threaten you with violence, let alone actually harm you?

      Have you ever had a gun stuck in your face over $20, $40, $60? Do you know how many people get killed by violent thugs, for even less, or even nothing?

      You break into my house, you’re leaving feet first.

      (Now, I’m not talking about the stupid drunks who in the case above, I think that’s a special case, and once you surrender to intoxicants you lose all kinds of rights and presumptions of righteousness).

  9. The most common type of trespass in the home of another occurs when an ex-spouse shows up to pick up a child for a scheduled parental outing day. Courts do not like to get into scheduling these matters and other social bureaucracies have plenty else to do, so oftentimes it falls to the adults themselves to settle in a reasonable manner all the adjustments that life will require to be made to the most rigid visitation plan.

    Confrontations happen. Compounding this is the fact that often the name of both parties is still on the deed or the lease or whatever. Psychologically, people don’t retreat from what they still feel in their heart their own sweat has paid for.

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