In People v. Lilly, 38 Mich 270 (1878), the defendant discharged one of his farmhands, and a dispute developed regarding how much the defendant owed the farmhand for his last wages. When the two encountered each other in town, the farmhand threatened the defendant. Id. Later that evening, the farmhand went to the defendant's home to retrieve his belongings and ran into the defendant outside in "the passage way between" the defendant's old home and a new home he was building "a few feet" away. Id. at 274. The dispute over the farmhand's wages erupted again, and other workers overheard the defendant telling the farmhand to "take his hands off and not strike him again." Id. at 274-275. A struggle ensued, and the defendant stabbed the farmhand with a pocket knife, killing him. Id. at 275. At trial, the court instructed the jury that if the defendant "could have saved himself from all serious harm by retreating or calling for assistance," but did not do so, and, instead, "stood his ground and resisted," the killing would not be justifiable or excusable. Id. at 275. The Supreme Court ordered a new trial after holding that the instruction was "improper and misleading" because it suggested to the jury that "it was incumbent upon the defendant to fly from his habitation where his wife and children were, in order to escape danger instead of resisting the aggressor. Such is not the law." The Court opined that, "in these cases of personal peril," the person attacked has a right and a duty to defend himself, and the law does not impose "any obligation to remain supine and attempt to shift this duty upon other private persons" who have no obligation to help. Id. at 276-277. In Lilly, the primary focus was not on the no-duty-to-retreat rule, but rather on self defense. The Court was concerned that the trial court had instructed the jury that: (1) the defendant had to call for assistance from others and wait to see if others would come to his aid before he could exercise self defense; (2) that the defendant had to flee from his home to resist the aggressor even though in doing so, his wife and children would remain there at the mercy of the aggressor. The Lilly Court never said that the defendant was entitled to a no-duty-to-retreat instruction.