Geoffrey Quarles v. State of Indiana (mem. dec.)
49A02-1605-CR-1187
Ind. Ct. App.Jan 20, 2017Background
- On May 22, 2015, Geoffrey Quarles and a friend were at a bar; as the bar closed Quarles drew a legally owned handgun and fired toward the bar.
- Christian Canelas, a security worker, was standing in the parking lot between Quarles and the bar when Quarles fired; Canelas testified the shot was aimed at a roughly 45-degree angle toward the club.
- After firing, Quarles left; police located and stopped him shortly thereafter based on a dispatch, and Canelas identified him as the shooter.
- The State charged Quarles with Level 6 felony criminal recklessness for creating a substantial risk of bodily injury to Canelas; a jury convicted him.
- The trial court reduced the conviction under Indiana’s Alternate Misdemeanor Sentencing statute to an A misdemeanor and sentenced Quarles to 365 days suspended to probation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Quarles created a substantial risk of bodily injury to Canelas | Shooting toward the bar, with Canelas between shooter and bar, created a substantial risk (including risk of ricochet) | Shot was aimed over the building and did not put Canelas in danger | Jury reasonably could find Quarles created a substantial risk; evidence sufficient to support conviction |
| Sufficiency of evidence to rebut self-defense claim | State argued it disproved at least one element of self-defense (no reasonable fear or provocation) | Quarles claimed he fired warning shots to defend against an advancing, threatening crowd | Factfinder could disbelieve Quarles’ account; State presented sufficient evidence to rebut self-defense |
Key Cases Cited
- Elliot v. State, 560 N.E.2d 1266 (Ind. Ct. App. 1990) (reversed recklessness conviction where shots were fired over uninhabited areas)
- Boushehry v. State, 648 N.E.2d 1174 (Ind. Ct. App. 1995) (no substantial risk where defendant shot geese in a field with no one near line of fire)
- Woods v. State, 768 N.E.2d 1024 (Ind. Ct. App. 2002) (firing in close proximity to people can create a risk via ricochet)
- Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (standard of review for sufficiency to rebut self-defense)