Darrell Brooks v. State of Indiana (mem. dec.), 49A02-1703-CR-403

Darrell Brooks and Sandra Young ended a nine-year relationship; on Oct. 5, 2016 Brooks went to their former apartment to retrieve belongings and an argument ensued.
The verbal dispute became physical: Young testified Brooks pushed her in the upper chest/neck area, causing her to fall; she then swung at him and made contact.
Young further testified Brooks grabbed a wooden paint-extension stick and struck her across the back, causing pain and bruising.
The State charged Brooks with Level 6 felony domestic battery (moderate bodily injury) and two Class A misdemeanor battery counts; Brooks waived a jury trial.
After a bench trial, the court convicted Brooks of the Level 6 felony (merging the misdemeanors) and sentenced him to 545 days with 180 executed.
On appeal Brooks argued the State failed to disprove his claim of self-defense; the court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved beyond a reasonable doubt that Brooks did not act in self-defense	State: evidence showed Brooks instigated and escalated the violence, rebutting self-defense	Brooks: he acted in self-defense after being the victim of aggression	Court: Affirmed — evidence (Young's testimony) sufficiently negated self-defense

Wallace v. State, 725 N.E.2d 837 (Ind. 2000) (defines self-defense as legal justification and frames sufficiency review)
Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (elements required to claim self-defense and reversal standard)
King v. State, 61 N.E.3d 1275 (Ind. Ct. App. 2016) (State’s burden to negate at least one element when self-defense is raised)
Adetokunbo v. State, 29 N.E.3d 1277 (Ind. Ct. App. 2015) (standard for sufficiency review: consider probative evidence and reasonable inferences)
Wolf v. State, 76 N.E.3d 911 (Ind. Ct. App. 2017) (discussion of sufficiency to negate self-defense)