Ron C. Stewart v. State of Indiana (mem. dec.), 49A02-1604-CR-740

On May 3, 2015, Ron C. Stewart, driving a Dodge Durango, cut off two motorcycles; after a verbal confrontation at a red light he brandished a handgun and later drove into a pawn‑shop lot where the motorcyclists followed.
Norris struck Stewart’s Durango with a ‘‘monkey ball’’ (key‑chain type object). Stewart then walked to the rear of his vehicle and fired six shots toward the motorcyclists; Norris was shot (including in the back of the head) and died en route to the hospital.
Stewart fled, stayed at his mother’s house, then a hotel; post‑arrest evidence included internet searches about “duty to retreat” and “stand your ground.”
Charged with murder (later, jury acquitted of murder but convicted of the lesser included Level 2 voluntary manslaughter). Trial court sentenced Stewart to 14 years (10 executed).
On appeal Stewart argued (1) the State failed to disprove his self‑defense claim beyond a reasonable doubt and (2) the trial court erred in refusing his proposed self‑defense jury instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency to disprove self‑defense	State: evidence shows Stewart was initial/mutual aggressor, had opportunity to retreat, and used excessive force	Stewart: he reasonably feared for his life and acted in self‑defense; State did not negate this beyond a reasonable doubt	Affirmed — jury could reasonably find self‑defense negated by evidence (mutual combatant, retreat possible, shot victim in back of head)
Jury instruction on self‑defense	State: pattern instruction correctly states law and covers burden of proof	Stewart: requested instruction was necessary to tell jury to acquit if State failed to disprove self‑defense	Affirmed — trial court did not abuse discretion; Indiana pattern instruction properly instructed jury

Wallace v. State, 725 N.E.2d 837 (Ind. 2000) (standard for self‑defense as legal justification and burden shifting)
Wilson v. State, 770 N.E.2d 799 (Ind. 2002) (review standard for sufficiency in self‑defense cases)
Walker v. State, 998 N.E.2d 724 (Ind. 2013) (appellate review: do not reweigh evidence or assess credibility)
King v. State, 61 N.E.3d 1275 (Ind. Ct. App. 2016) (once defendant raises self‑defense, State must negate at least one element)
Porter v. State, 543 N.E.2d 390 (Ind. 1989) (self‑defense unavailable where retreat was possible)
Jordan v. State, 656 N.E.2d 816 (Ind. 1995) (shooting victim in the back undermines claim of reasonable fear)
Sudberry v. State, 982 N.E.2d 475 (Ind. Ct. App. 2013) (mutual combatant who fails to withdraw cannot claim self‑defense)
Washington v. State, 997 N.E.2d 342 (Ind. 2013) (pattern jury instruction on self‑defense correctly states law)