Randol Thomas Palmer-Hall v. State of Indiana (mem. dec.), 138 N.E.3d 968

On June 1, 2018 Hammond PD Officer Daniel Sangkaratana, in uniform and driving a marked cruiser with emergency lights, responded to a dispatch about a man who allegedly tried to grab a woman.
Officer stopped an SUV matching the description; Palmer-Hall exited the driver seat, reached under the seat, and a struggle ensued when the officer grabbed his hand.
Body‑cam and dash‑cam footage (about 30 seconds) show a physical altercation in the doorway and street; officer testified his belt twisted and equipment (body mic, shoulder mic) was ripped off during the struggle.
Bystander Patrick Baum intervened and stated it looked like Palmer‑Hall was trying for the officer’s gun, though he acknowledged he did not clearly see a reach for the gun prior to intervening.
Palmer‑Hall was charged with disarming a law enforcement officer (Level 5 felony), battery against a public safety official (Level 6 felony), resisting law enforcement (Class A misdemeanor), and other counts; at trial the court denied Palmer‑Hall’s proposed mistake‑of‑fact jury instruction.
Jury convicted Palmer‑Hall of disarming, battery against a public safety official, resisting, and battery; the Court of Appeals affirmed, rejecting both the instruction challenge and sufficiency challenge to the disarming conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing defendant’s proposed mistake‑of‑fact instruction	No abuse: record and video show officer plainly identifiable; no evidence of defendant’s honest belief he was not dealing with police, so instruction unsupported	Court refused to consider defendant’s subjective belief; he was in an unwell state and reasonably mistook the officer for a civilian, so instruction was required	Affirmed. No evidentiary foundation for mistake‑of‑fact instruction; trial court did not abuse discretion
Whether evidence was sufficient to sustain conviction for disarming a law enforcement officer	Evidence sufficient: officer felt belt twist, equipment torn off, bystander perceived attempt for gun; video and testimony permit reasonable inference of attempted removal of weapon	Testimony was speculative; video doesn’t clearly show reaching for the gun and bystander expressed doubt—insufficient to prove attempt beyond reasonable doubt	Affirmed. Viewing evidence and reasonable inferences in favor of the verdict, a jury could find attempt to take officer’s firearm beyond a reasonable doubt

Overstreet v. State, 783 N.E.2d 1140 (Ind. 2003) (trial court has discretion on jury instructions; standard for reviewing instruction rulings)
Huls v. State, 971 N.E.2d 739 (Ind. Ct. App. 2012) (defendant entitled to instruction on any defense with some foundation in evidence)
Potter v. State, 684 N.E.2d 1127 (Ind. 1997) (allocation of burden when defendant raises a defense requiring evidentiary predicate)
Barton v. State, 936 N.E.2d 842 (Ind. Ct. App. 2010) (elements of mistake‑of‑fact defense: honest and reasonable belief, factual mistake, and negation of required culpability)
Chavers v. State, 991 N.E.2d 148 (Ind. Ct. App. 2013) (when State makes prima facie case, defendant must establish evidentiary predicate for mistake‑of‑fact)
Stoner v. State, 442 N.E.2d 983 (Ind. 1982) (evidence relevant to a defense must be capable of creating reasonable doubt about requisite mental state)
Jordan v. State, 656 N.E.2d 816 (Ind. 1995) (standard for sufficiency review — do not reweigh evidence or judge credibility)