Rebecca Lawson v. State of Indiana (mem. dec.)
49A02-1703-CR-445
| Ind. Ct. App. | Nov 20, 2017Background
- On Feb. 12, 2016 Rebecca Lawson went to Patrick Brown’s house to retrieve a handgun she had loaned him; Brown and Cecelia Land were present.
- Lawson kept a handgun in her purse and placed it in her lap when she parked; an interaction ensued in which Brown reached into the car, attempted to grab the gun, and later grabbed and squeezed Lawson’s face.
- Fearing for her safety, Lawson fired, hitting Brown (who later died) and Land (who suffered severe, disfiguring injuries).
- Lawson was charged with murder and attempted murder; she raised self-defense at trial and the court and parties discussed giving a self-defense jury instruction.
- The trial court indicated it would give the pattern self-defense instruction, and the State agreed; however, the final jury instructions did not include any self-defense instruction and no party objected at trial.
- Lawson was convicted by a jury and sentenced to an aggregate 85 years; on appeal she argued the omission of a self-defense instruction was fundamental error requiring reversal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court’s failure to give a self-defense instruction constituted fundamental error | State: omission not preserved; reversal only if fundamental error; no plain prejudice shown | Lawson: evidence supported self-defense instruction; court intended to give it; omission left jury without elements and denied fair trial | Court: Reversed and remanded — failure to give the instruction was fundamental error because evidence supported self-defense, parties argued it, court intended to give it, and omission made a fair trial impossible |
Key Cases Cited
- Pattison v. State, 54 N.E.3d 361 (Ind. 2016) (standard for review of unpreserved instructional errors and fundamental error framework)
- Halliburton v. State, 1 N.E.3d 670 (Ind. 2013) (fundamental-error exception is narrow; reversal only in egregious circumstances rendering a fair trial impossible)
- Whiting v. State, 969 N.E.2d 24 (Ind. 2012) (fundamental error reflects trial judge’s failure to act when required)
- Hernandez v. State, 45 N.E.3d 373 (Ind. 2015) (defendant entitled to jury instruction on any defense with some foundation in the evidence)
- Wright v. State, 730 N.E.2d 713 (Ind. 2000) (preservation rule for instructional defects; unpreserved errors reviewed only for fundamental error)