Tyrone Causey v. State of Indiana
2015 Ind. App. LEXIS 719
| Ind. Ct. App. | 2015Background
- Anonymous 911 call reported a disturbance at Causey's residence; officers found broken storm door glass but heard nothing inside
- Causey refused entry and warned officers to stay away, stating they had no right there and later said they wouldn’t take him alive
- Causey opened the door multiple times, yelled at officers, and made statements suggesting he would shoot if they entered or approached
- SAWT team responded; Causey’s fiancée arrived with child; officers treated as hostage situation; Causey was arrested alone in the home
- Causey was convicted of Class D felony intimidation; conviction reversed on appeal due to lack of evidence of intent to place officers in fear for a prior lawful act
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved intent to place in fear for a prior lawful act | Causey argues no prior lawful act by officers justified fear | Causey contends threat aimed at future acts, not prior lawfully engaged acts | reversed; insufficient evidence of required intent to fear for a prior act |
| Whether Causey's statements constituted a threat under the statute | State argues explicit threat to shoot the officers | No clear, unlawful-threat language tied to prior lawful act; ambiguous/unclear statements | reversed; threats not clearly proven as required by statute |
| Whether surrounding circumstances could support intent inference | State points to agitation and past conduct as circumstantial support | Court should not infer intent from ambiguous, future-oriented statements | reversed; totality of circumstances insufficient to prove the required intent |
Key Cases Cited
- Casey v. State, 676 N.E.2d 1069 (Ind. Ct. App. 1997) (requires proof of intent to retaliate for a prior lawful act; not future conduct)
- Gaddis v. State, 680 N.E.2d 860 (Ind. Ct. App. 1997) (intent may be inferred from surrounding circumstances but must be reasonable)
- Ransley v. State, 850 N.E.2d 443 (Ind. Ct. App. 2006) (no reweighing; consider evidence favorable to verdict; may not substitute view of witnesses)
- Tuberville v. Savage, 1 Mod. Rep. 3 (K.B.) (1669) (illustrative of conditional statements not constituting threats)
- Hightower v. State, 866 N.E.2d 356 (Ind. Ct. App. 2007) (intent must be inferred reasonably from surrounding evidence)
- George v. NCAA, 945 N.E.2d 150 (Ind. 2011) (due process requires clear statutory proscription and notice)