Logan Sabik v. State of Indiana (mem. dec.)
49A02-1705-CR-907
| Ind. Ct. App. | Oct 4, 2017Background
- In December 2016, Logan Sabik and his aunt Stephanie were arguing at home; Stephanie’s girlfriend Ashley Howard intervened after returning from work.
- Stephanie initially put hands on Sabik to direct him away from Howard; Sabik then charged at Howard, knocked her down, and twice body-slammed her.
- Howard, with a martial-arts background, initially put Sabik in a headlock to restrain him; Sabik freed himself and escalated the assault.
- Howard suffered minor injuries; police were called and the State charged Sabik with class A misdemeanor battery (Howard) and class B misdemeanor battery (Stephanie).
- At a bench trial Sabik asserted self-defense; the court found him guilty of the class A misdemeanor as to Howard, acquitted on the count involving Stephanie, and imposed a one-year fully suspended sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State rebutted Sabik’s self-defense claim | State: evidence shows Sabik was initial aggressor and provoked the violence, negating self-defense | Sabik: he acted in self-defense to protect himself from imminent unlawful force | The trial court reasonably credited State’s evidence; self-defense was negated and conviction affirmed |
Key Cases Cited
- Wolf v. State, 76 N.E.3d 911 (Ind. Ct. App. 2017) (standard for reviewing sufficiency when self-defense asserted)
- A.A. v. State, 29 N.E.3d 1277 (Ind. Ct. App. 2015) (do not reweigh evidence or judge credibility on appeal)
- Dixson v. State, 22 N.E.3d 836 (Ind. Ct. App. 2014) (elements required to claim self-defense when non-deadly force is involved)
- Wallace v. State, 725 N.E.2d 837 (Ind. 2000) (self-defense as legal justification for otherwise criminal acts)
- Miller v. State, 720 N.E.2d 696 (Ind. 1999) (initial aggressor generally not entitled to self-defense)
- King v. State, 61 N.E.3d 1275 (Ind. Ct. App. 2016) (State bears burden to negate at least one element of self-defense)
- Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (conviction stands unless no reasonable person could find self-defense negated)
- Barton v. State, 490 N.E.2d 317 (Ind. 1986) (trial court entitled to resolve conflicting witness accounts)
- McCullough v. State, 985 N.E.2d 1135 (Ind. Ct. App. 2013) (clarifies fear of death/serious harm requirement applies principally to deadly-force cases)