Demeko Bradley v. State of Indiana (mem. dec.), 82A01-1602-CR-294

Shortly after midnight on Dec. 27, 2014, Demeko Bradley walked around the rear of a Tahoe at a gas station, moved Erin Harvell aside, drew a gun, fired five shots at Decedric Williams, and fled the scene; Williams later died of a gunshot to the abdomen.
Surveillance video captured Bradley stepping around Harvell, drawing a handgun with his right hand, and firing before running behind the Tahoe.
Prosecution introduced crime-scene photos, a post-mortem hospital photograph, an autopsy report (showing multiple gunshot wounds and fatal abdominal wound), and witness testimony from Harvell, Derrick Johnson, Bradley, and police.
Bradley claimed self-defense, arguing Williams had previously brandished a gun and was turning toward him at the gas station.
A jury convicted Bradley of murder; he admitted being an habitual offender. The trial court sentenced him to 60 years for murder plus a 10-year habitual-offender enhancement.
On appeal Bradley raised (1) sufficiency of the evidence to disprove self-defense, (2) trial-court admission of a hospital photograph, and (3) whether his sentence is inappropriate under Appellate Rule 7(B).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bradley)	Held
Sufficiency to negate self-defense	Evidence (video, witnesses, autopsy, flight, multiple shots) permits a jury to find Bradley did not reasonably fear death or used excessive force	Video and autopsy only show a homicide; video doesn’t establish provocation or that fear was unreasonable	Affirmed: reasonable juror could reject self-defense based on video, testimony, and circumstances
Admission of hospital photograph (State’s Ex. 32)	Photograph was relevant to show gunshot wounds and aid jury understanding; not unduly prejudicial	Defense had stipulated to death/cause; the post-mortem photo was cumulative and unfairly prejudicial under Evid. R. 403	No abuse of discretion: probative value outweighed prejudice; photo was not particularly gruesome and aided testimony
Sentence appropriateness under Ind. App. R. 7(B)	Sentence (60 + 10 yrs) fits offense severity and offender’s record (prior felonies, high risk to reoffend, fled state)	Bradley argued lack of violent history and mitigating context (prior threat by victim) support a lesser sentence	Affirmed: defendant failed to show aggregate sentence inappropriate given nature of offense and character

Jordan v. State, 656 N.E.2d 816 (Ind. 1995) (standard for sufficiency review; do not reweigh evidence)
Ferrell v. State, 565 N.E.2d 1070 (Ind. 1991) (uncorroborated testimony can sustain a conviction)
Beatty v. State, 567 N.E.2d 1134 (Ind. 1991) (intent may be inferred from circumstantial evidence)
Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (elements and burden-shifting for a self-defense claim)
Harmon v. State, 849 N.E.2d 726 (Ind. Ct. App. 2006) (force must be reasonably necessary; excessive force extinguishes self-defense)
Wallace v. State, 725 N.E.2d 837 (Ind. 2000) (sufficiency to rebut self-defense; appellate deference to jury)
Milam v. State, 719 N.E.2d 1208 (Ind. 1999) (affirming murder conviction where evidence supported finding no reasonable fear)
Birdsong v. State, 685 N.E.2d 42 (Ind. 1997) (initial aggression not dispositive; unreasonable deadly force can negate self-defense)
Rodriguez v. State, 714 N.E.2d 667 (Ind. Ct. App. 1999) (conflicting testimony does not require reversal)
Helsley v. State, 809 N.E.2d 292 (Ind. 2004) (trial court’s discretion to admit photographs; balance probative value vs. unfair prejudice)
Corbert v. State, 764 N.E.2d 622 (Ind. 2002) (photographs admissible if relevant and aid jury)
Reaves v. State, 586 N.E.2d 847 (Ind. 1992) (defendant not entitled to sanitized presentation of evidence)
Childress v. State, 848 N.E.2d 1073 (Ind. 2006) (standard and burden for Appellate Rule 7(B) sentence review)