Isaiah Levert Hughes v. State of Indiana (mem. dec.), 45A03-1606-CR-1317

On July 12–13, 2013, at a party in Gary, Indiana, a physical altercation occurred between Isaiah Hughes and B.J. Fullilove; the fight lasted several minutes and witnesses disputed who started it.
Hughes’s wife allegedly pointed and swung a gun toward Fullilove’s direction during the incident.
After the fight, Hughes ran to his vehicle and fired four shots at Fullilove; Fullilove later died from his injuries.
Hughes voluntarily confessed to firing the shots at the police station and was charged on August 27, 2013 with felony murder.
At trial (Feb. 8–12, 2016), the State requested a jury instruction for voluntary manslaughter as a lesser included offense; the trial court gave the instruction over Hughes’s objection.
The jury convicted Hughes of voluntary manslaughter; he was sentenced to 25 years (20 executed, 5 suspended). Hughes appealed, arguing the instruction on voluntary manslaughter was improper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly instructed the jury on voluntary manslaughter as a lesser offense of murder	State: Any appreciable evidence of "sudden heat" justified the instruction	Hughes: No sufficient evidence of sudden heat; instruction improperly given	Court: Instruction proper — record contained appreciable evidence of sudden heat

Patton v. State, 837 N.E.2d 576 (instructional error standard for jury charges)
Clark v. State, 834 N.E.2d 153 (three-step analysis for lesser-included offense instructions)
Wright v. State, 658 N.E.2d 563 (requirement to give lesser-offense instruction when evidentiary dispute exists)
Roberson v. State, 982 N.E.2d 452 (voluntary manslaughter requires proof of murder plus appreciable evidence of sudden heat)
Washington v. State, 808 N.E.2d 617 (any appreciable evidence of sudden heat justifies manslaughter instruction)