Candelario Cruz-Trujillo v. State of Indiana (mem. dec.)
41A01-1612-CR-2723
| Ind. Ct. App. | Oct 26, 2017Background
- Defendant Candelario Cruz-Trujillo discovered his wife was having an affair with Miguel Hernandez; tensions escalated over child custody and repeated provocations by Hernandez.
- On the night of Sept. 29–30, 2015, after drinking and cutting his hand, Candelario drove to Hernandez's workplace, waited, confronted him, then fired multiple shots; after Hernandez fell, Candelario shot him again in the head and fled.
- Candelario was charged with murder; a jury trial was held in Sept. 2016, resulting in a conviction and a 56-year sentence.
- At trial the court refused defense requests for jury instructions on involuntary manslaughter, voluntary manslaughter, and reckless homicide.
- On appeal, Candelario argued the court abused its discretion by excluding those lesser-included-offense instructions.
- The Court of Appeals affirmed, holding the record did not support giving those instructions under Indiana law.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Cruz-Trujillo) | Held |
|---|---|---|---|
| Whether involuntary manslaughter instruction was required | Charging information alleges knowing/intentionally killing only; no battery alleged; no evidentiary dispute supporting batter intent | Probable cause affidavit showed battery (shooting) so involuntary manslaughter is factually included and instruction warranted | Trial court properly refused; charging information did not allege battery and evidence showed intent to kill not merely battering |
| Whether voluntary manslaughter (sudden heat) instruction was required | No sufficient provocation or contemporaneous passion; defendant planned and waited, indicating deliberation | Defendant acted under sudden heat/terror and intoxication could have obscured judgment | Trial court properly refused; evidence showed premeditation and no sudden heat to mitigate to voluntary manslaughter |
| Whether reckless homicide instruction was required | Murder proven by knowing/intentional conduct; defendant's statements and conduct show awareness of high probability of death | Confronting an affair partner while intoxicated and armed creates a factual dispute whether killing was reckless rather than knowing | Trial court properly refused; evidence supported intentional/knowing killing and no serious dispute about mental state |
Key Cases Cited
- Wilson v. State, 765 N.E.2d 1265 (Ind. 2002) (three-part test for lesser-included-offense instructions)
- Wright v. State, 658 N.E.2d 563 (Ind. 1995) (framework for when lesser-included instructions are required)
- Webb v. State, 963 N.E.2d 1103 (Ind. 2012) (distinguishing murder and reckless homicide; evidentiary dispute on mens rea required)
- Washington v. State, 808 N.E.2d 617 (Ind. 2004) (sudden heat standard for voluntary manslaughter)
- Evans v. State, 727 N.E.2d 1072 (Ind. 2000) (involuntary manslaughter requires intent to batter)
- Leon v. State, 525 N.E.2d 331 (Ind. 1988) (firing weapon at victim permits inference of intent to kill)
- Fuentes v. State, 10 N.E.3d 68 (Ind. Ct. App. 2014) (intent to kill may be inferred from deadly weapon use and surrounding circumstances)
- Collins v. State, 966 N.E.2d 96 (Ind. Ct. App. 2012) (voluntary manslaughter instruction appropriate when sudden heat is supported by evidence)
- Champlain v. State, 681 N.E.2d 696 (Ind. 1997) (charging information that omits battery precludes involuntary manslaughter instruction)
- Schweitzer v. State, 531 N.E.2d 1386 (Ind. 1989) (probable cause affidavit serves pretrial detention purpose separate from charging instrument)
- Norris v. State, 943 N.E.2d 362 (Ind. Ct. App. 2011) (involuntary manslaughter factually included if information alleges battery caused death)
- Newman v. State, 751 N.E.2d 265 (Ind. Ct. App. 2001) (reckless homicide instruction not warranted when defendant admitted pointing and firing a gun)
- Suprenant v. State, 925 N.E.2d 1280 (Ind. Ct. App. 2010) (deliberation undermines sudden heat claim)