Billy Campbell v. State of Indiana (mem. dec.)
49A02-1601-CR-97
| Ind. Ct. App. | Sep 30, 2016Background
- On Aug. 15, 2015, after a fair, Billy Campbell (driver of a white van) and Chelsea Lipe had a road‑rage confrontation; Lipe honked and yelled after the van tried to pass her.
- Campbell stopped abruptly; both parties exited their vehicles and argued face‑to‑face. Lipe did not hit Campbell.
- Campbell punched Lipe in the face, causing her to fall, lose a tooth, and suffer a fractured jaw; Lipe’s husband had retrieved a tire jack but had not yet reached them when the punch occurred.
- Campbell returned to his van at his son’s urging and drove off; Lipe’s husband smashed the van’s rear window and the Lipes contacted police; Campbell was stopped and arrested.
- Campbell was charged with and convicted by the bench of battery (Class A misdemeanor); he appealed, asserting the State failed to rebut his claim of self‑defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State presented sufficient evidence to rebut Campbell’s self‑defense claim | State: evidence shows Campbell instigated confrontation and struck an unarmed Lipe, negating self‑defense | Campbell: Lipe and her husband were aggressors (Lipe swinging arms; husband with tire jack) | Affirmed: State presented sufficient evidence rebutting self‑defense; conviction upheld |
Key Cases Cited
- Miller v. State, 720 N.E.2d 696 (Ind. 1999) (State may rebut self‑defense by relying on sufficiency of evidence in chief)
- Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (standard for reviewing sufficiency to negate self‑defense)
- Cole v. State, 28 N.E.3d 1126 (Ind. Ct. App. 2015) (upholding conviction where victim testified defendant struck first despite defendant’s contradictory testimony)
- Huls v. State, 971 N.E.2d 739 (Ind. Ct. App. 2012) (same standard of review for sufficiency when self‑defense claimed)
- Bryant v. State, 984 N.E.2d 240 (Ind. Ct. App. 2013) (elements required to establish statutory self‑defense)
