In the case of Brown v. United States in 1927, the Supreme Court ruled that a person who kills another in self-defense while being attacked at their place of work can claim immunity from prosecution under federal law. The defendant, Brown, was indicted for murder after shooting and killing one man and injuring another who had threatened him with death on multiple occasions and were trespassing on his property to carry out their threats when he shot them. The court held that a person is not obligated to retreat if they are attacked within any place where they have a right to be (including their workplace), and may use as much force as reasonably necessary to save themselves from serious injury or death without exceeding "the bounds set by the necessity which justifies his act." This ruling expanded upon previous interpretations of self-defense laws which generally only applied this principle ("no duty to retreat") within one's own home.

In the dissenting opinion for Brown v. United States, Justice Oliver Wendell Holmes argued that the defendant should not have been convicted of murder because he was acting in self-defense. He believed that a person has a right to stand their ground and protect themselves when they are being attacked, even if it results in killing the attacker. According to Holmes, this principle applies regardless of whether or not one could have safely retreated from the situation instead of resorting to violence. The majority's decision contradicted this principle by suggesting that people must retreat whenever possible before using deadly force in self-defense. This view undermines an individual’s fundamental right to defend oneself against imminent harm or danger.