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Juventino Vargas-Rodriguez v. State of Indiana (mem. dec.)
71A03-1609-CR-2118
| Ind. Ct. App. | Aug 9, 2017
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Background

  • In the early morning hours of September 6, 2015, Juventino Vargas-Rodriguez and Jorge Garcia had an altercation outside a South Bend club; Garcia left in a gray truck.
  • Vargas-Rodriguez retrieved his white Chevrolet Impala, picked up three friends (including Ricardo Ramirez and Manuel Vargas), and began searching for Garcia's truck.
  • While chasing the truck, Ramirez (a rear-seat passenger) fired multiple rounds at the truck; most struck the rear before the truck turned onto Sample Street.
  • Ramirez reloaded, and when Vargas-Rodriguez pulled up side-by-side on Olive Street, Ramirez fired two more shots, one of which struck Garcia in the head; Garcia later died.
  • Vargas-Rodriguez was charged as an accomplice to murder, tried by a jury (which was instructed on murder and reckless homicide), convicted of murder, and sentenced to 50 years.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of evidence to support murder conviction vs. reckless homicide State: evidence supports that Vargas-Rodriguez knowingly or intentionally participated in killing by chasing, enabling Ramirez’s shots, and knowing Ramirez had a gun Vargas-Rodriguez: conceded accomplice liability but argued the State failed to prove intent/knowledge required for murder and that only reckless homicide is supported Court affirmed: evidence sufficient for murder; Vargas-Rodriguez knew high probability Ramirez could kill someone and aided the fatal shots

Key Cases Cited

  • Sallee v. State, 51 N.E.3d 130 (Ind. 2016) (standard for appellate sufficiency review; consider evidence and reasonable inferences supporting the verdict)
  • Drane v. State, 867 N.E.2d 144 (Ind. 2007) (deference to factfinder on witness credibility and weighing evidence)
Read the full case

Case Details

Case Name: Juventino Vargas-Rodriguez v. State of Indiana (mem. dec.)
Court Name: Indiana Court of Appeals
Date Published: Aug 9, 2017
Docket Number: 71A03-1609-CR-2118
Court Abbreviation: Ind. Ct. App.