Jeffrey D. Pruitt v. State of Indiana

CourtIndiana Court of Appeals
DecidedJune 19, 2012
Docket20A05-1110-CR-576
StatusUnpublished

This text of Jeffrey D. Pruitt v. State of Indiana (Jeffrey D. Pruitt v. State of Indiana) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffrey D. Pruitt v. State of Indiana, (Ind. Ct. App. 2012).

Opinion

Pursuant to Ind.Appellate Rule 65(D), this Memorandum Decision shall not be

FILED regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, Jun 19 2012, 9:14 am collateral estoppel, or the law of the case. CLERK of the supreme court, court of appeals and tax court

ATTORNEY FOR APPELLANT: ATTORNEYS FOR APPELLEE:

PETER D. TODD GREGORY F. ZOELLER Elkhart, Indiana Attorney General of Indiana

NICOLE M. SCHUSTER Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

JEFFREY D. PRUITT, ) ) Appellant-Defendant, ) ) vs. ) No. 20A05-1110-CR-576 ) STATE OF INDIANA, ) ) Appellee-Plaintiff. )

APPEAL FROM THE ELKHART SUPERIOR COURT The Honorable Evan S. Roberts, Judge Cause No. 20D01-0809-FC-67

June 19, 2012

MEMORANDUM DECISION - NOT FOR PUBLICATION

BARNES, Judge Case Summary

Jeffrey Pruitt appeals his conviction for Class C felony criminal recklessness. We

affirm.

Issues

Pruitt raises two issues, which we restate as:

I. whether the trial court properly rejected his tendered self-defense instruction; and

II. whether the manner in which the jury was instructed on self-defense resulted in fundamental error.

Facts

In December 2007, Pruitt had been romantically involved with Sabrina Hardesty

and was living with her and her two daughters in her apartment in Elkhart. The romantic

relationship ended and, despite Sabrina’s request, Pruitt did not move out of the

apartment. On December 5, 2007, Sabrina asked two of her brothers, Adrian and

Archibald, to help her get Pruitt to leave the apartment.

Adrian, Archibald, and a friend, Jeff DeVore, arrived at the apartment while

Sabrina was getting her young daughters ready for a Christmas program. Pruitt was

sitting on the couch when the men arrived. Archibald told Pruitt it was time to move out,

and Pruitt explained he had nowhere to go and questioned “who the heck was [Archibald]

to tell him what to do.” Tr. p. 570. A physical fight ensued between Archibald and Pruitt

and, to some extent, Adrian. During the fight, Sabrina’s boyfriend, Billy Doolittle, and

another one of her daughters arrived at the apartment. Eventually the fight ended, and

Pruitt agreed to go upstairs to get his things.

2 Before going upstairs, Pruitt stated, “Somebody gonna die today.” Id. at 410.

After ten to fifteen minutes, Pruitt returned downstairs. At some point, apparently in an

attempt to trick Pruitt into believing he had a gun, Adrian instructed DeVore to go get a

gun from his car. DeVore left knowing there was no gun. When DeVore returned, he

remained on the landing outside the apartment and did not reenter. DeVore, however,

showed Pruitt he did not have a gun by pulling up his shirt, raising his hand in the air, and

saying, “I ain’t got nothing.” Id. at 414.

As Sabrina and Doolittle were leaving the apartment with the children for the

program, Pruitt made another threat and aimed a gun toward Sabrina and Doolittle.

Archibald attempted to disarm Pruitt and was shot in the head. Although Archibald

suffered a massive brain injury, he survived the shooting.

On September 5, 2008, the State charged Pruitt with Class C felony criminal

recklessness. At the conclusion of the September 2011 trial, a jury found Pruitt guilty as

charged. Pruitt now appeals.

Analysis

I. Refusal to Give Tendered Instruction

Pruitt argues that the trial court improperly refused to give his tendered self-

defense instruction. When a party has challenged a trial court’s refusal of a tendered jury

instruction, we perform a three-part evaluation to determine whether the trial court

abused its discretion. Walden v. State, 895 N.E.2d 1182, 1186 (Ind. 2008). “First, we

ask whether the tendered instruction is a correct statement of the law.” Id. Second, we

examine the record to determine whether there was evidence to support the tendered

3 instruction. Id. “Third, we determine whether the substance of the tendered instruction

was covered by another instruction or instructions.” Id. “An instruction that tends to

confuse the jury is properly rejected.” Dill v. State, 741 N.E.2d 1230, 1232 (Ind. 2001).

The jury was instructed on self-defense as follows:

It is an issue whether the Defendant acted in self-defense. A person may use reasonable force against another person to protect himself from what the Defendant reasonably believes to be the imminent use of unlawful force. A person is justified in using deadly force, and does not have a duty to retreat, only if he reasonably believes that the deadly force is necessary to prevent serious bodily injury to himself. However, a person may not use force if he provokes a fight with another person with intent to cause bodily injury to that person or he entered into a fight with another person or started the fight, unless he withdraws from the fight and communicates to the other person his intent to withdraw and the other person nevertheless continues or threatens to continue the fight. The State of Indiana has the burden of proving beyond a reasonable doubt that the Defendant did not act in self-defense.

App. p. 38. Pruitt’s tendered self-defense instruction provided:

Where defendant has belief that he is in danger of loss of life or great bodily harm, the fact that the danger was not real, but only apparent would not render defendant guilty, for question of apparent necessity can only be determined from standpoint of defendant at the time and under all the existing circumstances.

Id. at 65.

As the basis for his tendered instruction, Pruitt cited King v. State, 249 Ind. 699,

234 N.E.2d 465 (1968). A complete reading of the rule referenced in King, however,

requires that the danger appears to be real and that it is “‘reasonably believed’” by the

defendant to be real. King, 249 Ind. at 707, 234 N.E.2d at 469 (quoting Trogdon v. State,

4 133 Ind. 1, 7, 32 N.E. 725, 727 (1892)). Pruitt’s instruction did not include any reference

to a “reasonable belief” of an apparent danger. Thus, Pruitt’s tendered instruction is not a

correct statement of the law because it does not reference the objective standard of

reasonableness.

Even if the tendered instruction was a correct statement of the law, the evidence

did not support it. Pruitt asserts that, even if DeVore did not have a gun, the evidence

demonstrated that DeVore left the apartment to trick Pruitt into believing he had a gun.

Regardless, the evidence showed that DeVore never actually reentered the apartment and

remained on the landing outside the apartment and that DeVore showed Pruitt he did not

have a gun by waiving his hand, lifting up his shirt, and expressly saying he was

unarmed. Based on this evidence and the fact that Pruitt did not testify or otherwise

present any evidence regarding his subjective beliefs, we are not convinced that Pruitt’s

tendered instruction was supported by the evidence.

Finally, we disagree with Pruitt’s assertion that the jury was denied the

opportunity to judge the evidence from his standpoint because the jury was instructed to

consider what Pruitt reasonably believed in determining whether he was acting in self-

defense. See Littler v. State,

Related

Baker v. State
948 N.E.2d 1169 (Indiana Supreme Court, 2011)
Walden v. State
895 N.E.2d 1182 (Indiana Supreme Court, 2008)
Littler v. State
871 N.E.2d 276 (Indiana Supreme Court, 2007)
Dill v. State
741 N.E.2d 1230 (Indiana Supreme Court, 2001)
King v. State
234 N.E.2d 465 (Indiana Supreme Court, 1968)
Trogdon v. State
32 N.E. 725 (Indiana Supreme Court, 1892)

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