As we all know, individuals do not have the right to take another’s life. The law is clear and unambiguous as to that point. It is safe to say that the law values human life over all other individual rights ten-fold. This is why individuals are never allowed to kill people who come onto their land to steal or cause damage to the property. The law will always value life over things, and therefore provides us with very limited and defined exceptions to this rule. The biggest and most well-known exception is self-defense. Self-defense is the idea that an individual can use deadly force to protect themselves from another when the individual is in danger of being killed or extremely hurt by that person. But how far does this defense go? The Indiana Court of Appeals recently dealt with this question in its recent decision of Quinn v. State.1
In Quinn, the Court of Appeals was asked to overturn a conviction of attempted murder because the State failed to rebut the Defendant’s self-defense claim. In 2017, the Defendant, Quinn, went to the home of Darryl Boone and his fiancé. According to Quinn, he went over there to talk to them about some recent Facebook posts that were alarming. Upon arriving at Boone’s home, Quinn began banging on the front door. When asked who it was, Quinn refused to answer. Boone thereby armed himself with a handgun. Quinn too had a firearm in his possession. Quinn thereby proceeded to open the door, and the two individuals raised the firearms at each other. Quinn fired two shots at Boone and injured him. Quinn was subsequently charged with attempted murder. At trial, the prosecution introduced security video from Boone’s home, showing the exchange. The trial court thereby convicted Quinn of attempted murder. Quinn appealed.
On appeal, Quinn argued that the State failed to present evidence to rebut the specific elements of self-defense. The Court of Appeals, in affirming the decision, noted the three elements a defendant must show to prove self-defense. The Court found that the prosecution presented plenty of evidence to rebut the self-defense claim. Specifically, the fact that Quinn went to Boone’s home uninvited, knocked on his door for long period of time, and walked around the house holding a loaded firearm. The Court stated “[t]his evidence alone supports a finding that Quinn provoked, instigated, or willingly participated in the violence that subsequently ensued.” For those reasons, Quinn’s arguments failed, and the conviction was affirmed.
This case highlights the importance of staying up to date in the ever-changing legal landscape. Video evidence largely convicted this defendant. Knowing the status of developments in the law is the key to avoiding criminal liability, as well as being an engaged citizenry in our participatory system of government. This blog post on a key new case was written by attorneys at Ciyou & Dixon, P.C. who handle criminal defense cases and appeals of criminal convictions throughout the state. This blog is written for educational purposes only. It is not intended as legal advice or a solicitation for services. It is an advertisement.