80 (1877), was an Indiana court case that argued natural law and a distinct American Mind to reject a duty to retreat when claiming self-defense in a homicide case.

[1][2] On election night for the 1876 presidential race, John Runyan was harassed for being a Democrat by Charles Presnall when they were both in New Castle, Indiana.

Runyan shot and killed him with his revolver even though he could have retreated.

The court implied it was un-American,[2]: 551–2  writing of a referring to the distinct American mind,[1] "the tendency of the American mind seems to be very strongly against" a duty to retreat.

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