Charles Carlos Chatman v. State of Indiana (mem. dec.)
49A02-1606-CR-1205
| Ind. Ct. App. | Mar 10, 2017Background
- On December 24, 2015, Charles Chatman approached a liquor/bar where Vincent Vandivier worked; Vincent twice told Chatman to stop panhandling and to leave.
- A brief confrontation on the front step escalated: Vincent lightly pushed Chatman to create space; Vincent had a vapor cigarette in hand and placed that hand on his hip during the encounter.
- Chatman produced a knife, lunged, and stabbed Vincent in the lower left abdomen; Vincent ran into the bar and was later treated at a hospital (four staples).
- Ray Vandivier (owner) and others confronted Chatman outside; Ray drew a handgun but holstered it when Chatman began to move away; Chatman fled and was later apprehended by police with a bloody knife in his pocket.
- Chatman was charged with Level 5 felony battery by means of a deadly weapon, waived a jury trial, claimed self-defense at bench trial, and was convicted; he appealed arguing the State failed to disprove self-defense beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State disproved self-defense beyond a reasonable doubt | State: evidence shows Chatman was initial aggressor, not entitled to self-defense | Chatman: he was in a public place, did not provoke violence, reasonably feared great bodily harm after being pushed and perceived reach to waistband | Court: Affirmed conviction; State presented sufficient evidence to negate self-defense |
Key Cases Cited
- Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (standard for reviewing sufficiency to rebut self-defense and requirements for claiming self-defense)
- Henson v. State, 786 N.E.2d 274 (Ind. 2003) (self-defense as legal justification and elements required)
- Carroll v. State, 744 N.E.2d 432 (Ind. 2001) (State may rebut self-defense with evidence from its case-in-chief)
