Alacia Johnson v. State of Indiana (mem. dec.)
49A04-1611-CR-2486
Ind. Ct. App.Apr 11, 2017Background
- On January 3, 2016, at Limelight nightclub in Indianapolis, Alacia Johnson and Brooke Arnett Holman were involved in a physical altercation; Holman suffered a corneal abrasion after being struck in the left eye.
- Johnson was charged with Class A misdemeanor battery resulting in bodily injury.
- At the October 6, 2016 bench trial Johnson conceded involvement but asserted self-defense; Holman testified Johnson was the aggressor.
- Holman’s sister, JaLin Carter, corroborated that Johnson reached over a banister and punched Holman; Holman denied ever throwing a drink.
- The trial court found Johnson guilty, sentenced her to one year with credit for time served and the remainder suspended to probation, ordered no contact, and restitution.
- On appeal Johnson argued the State failed to disprove her claim of self-defense; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to disprove Johnson’s claim of self-defense and sustain a conviction for Class A misdemeanor battery (bodily injury) | State: Holman’s testimony, corroborated by Carter, showed Johnson was the instigator and inflicted the injury; this negates self-defense. | Johnson: She participated only in a brawl and acted in self-defense after someone threw a drink; the State failed to negate self-defense. | Court affirmed: a reasonable factfinder could find the State disproved self-defense and proved the elements beyond a reasonable doubt. |
Key Cases Cited
- Drane v. State, 867 N.E.2d 144 (standard for sufficiency review; consider evidence most favorable to verdict)
- Baker v. State, 968 N.E.2d 227 (assessing whether reasonable inferences support verdict)
- Stewart v. State, 768 N.E.2d 433 (appellate courts do not reweigh evidence or assess credibility)
- McEwen v. State, 695 N.E.2d 79 (elements required to claim self-defense)
- Wilson v. State, 770 N.E.2d 799 (conviction upheld unless no reasonable person could find self-defense negated)
- Hood v. State, 877 N.E.2d 492 (State may rebut self-defense by sufficiency of its case)
- Thompson v. State, 804 N.E.2d 1146 (trial court as trier-of-fact may credit witness testimony)
- McClendon v. State, 671 N.E.2d 486 (deference to factfinder credibility determinations)
- Moore v. State, 637 N.E.2d 816 (same)