• “Although Holmes's apothegm, "detached reflection cannot be demanded in the presence of an uplifted knife," is sometimes quoted, Holmes scholars have generally ignored the case of Brown v. United States. Holmes's opinion in Brown v. United States strongly upholds the bellicose doctrine of no duty to retreat-a bellicosity that apparently contradicts the values of civility and tolerance seen as the hallmarks of Holmes's classic opinions upholding the widely admired liberal doctrine of civil liberties.”