James Satterfield v. State of Indiana
2015 Ind. App. LEXIS 394
| Ind. Ct. App. | 2015Background
- Satterfield arrested and charged with murder in Indianapolis; he sought bail after arrest; trial court denied bail after a hearing with witnesses and exhibits; Satterfield has no prior criminal history and cooperated shortly after the incident; Brown was killed in a car where Satterfield was present with Biddle during an alleged encounter; hammer and DNA evidence linked Brown to the scene; the case proceeded to appeal and cross-appeal regarding bail and timeliness of the notice of appeal.
- The evidence shows Brown approached Satterfield’s car with a shiny object; Satterfield shot Brown in self-defense while Brown tried to enter the car; Brown’s body and Biddle’s belongings were found at the scene; Satterfield later turned himself in and gave a voluntary statement.
- The key procedural posture includes the State’s cross-appeal contesting timeliness of the appeal, and the appellate court’s decision to review merits despite late notice.
- The appellate court ultimately held that the right to bail is presumption of innocence with a high threshold in murder cases, and that Satterfield should be allowed to present self-defense evidence at a new bail hearing; it reverse the denial of bail and remand for a new hearing.
- The decision relies on Fry v. State (Indiana), which redefined the burden for bail in murder cases, and on historical Indiana bail precedents allowing examination of defenses in bail proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State must prove ‘evident’ proof or a strong presumption of guilt to deny bail in a murder case | Satterfield argues State bears burden to show evident proof or strong presumption. | Satterfield contends burden was shifted by Fry to the State. | Yes; the State must show evident proof or strong presumption, but defendant may present defenses. |
| Whether Satterfield could present self-defense evidence at the bail hearing | State argues defenses are not part of bail weighing. | Satterfield asserts he should be allowed to present self-defense evidence to rebut State’s burden. | Defendant must be allowed to present evidence of potential self-defense at bail. |
| Whether the State’s cross-appeal regarding timeliness of the notice of appeal should be heard on the merits | State argues timely notice required; timely appeal was forfeited. | Satterfield argues extraordinary circumstances warrant review. | Extraordinary reasons permitted review on the merits; appeal reversed and remanded. |
Key Cases Cited
- Fry v. State, 990 N.E.2d 429 (Ind. 2013) (shifted burden to State to show ‘evident’ proof or ‘strong’ presumption to deny bail in murder/treason cases)
- Ex Parte Moore, 30 Ind. 197 (Ind. 1868) (weigh evidence in bail proceedings to determine if proof is clear or presumption strong)
- State v. Hedges, 98 N.E.417 (Ind. 1912) (bail inquiry may consider evidence beyond indictment scope; mini-trial-like nature acknowledged)
- Phillips v. State, 550 N.E.2d 1290 (Ind. 1990) (affirms due process protections at bail hearings, including right to counsel and witnesses)
- Shuai v. State, 966 N.E.2d 619 (Ind. Ct. App. 2012) (reversed denial of bail where alternative explanations questioned credibility of evidence)
- Bozovichar v. State, 103 N.E.2d 680 (Ind. 1952) (early bail-right precedents cited for presumption of innocence)