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