Kevin S. Varner v. Warden

District Court, N.D. Indiana·Decided August 13, 2026·No. 3:25-cv-00815·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

KEVIN S. VARNER,

Petitioner,

v. CAUSE NO. 3:25cv815 DRL-SJF

WARDEN,

Respondent.

OPINION AND ORDER Kevin S. Varner, a prisoner without counsel, filed a habeas corpus petition challenging his 2023 conviction in Benton County for attempted aggravated battery, unlawful possession of a firearm by a serious violent felon, criminal recklessness, and resisting law enforcement under Case No. 04C01-2302-F1-052. For the following reasons, the petition is denied. BACKGROUND In deciding the petition, the court must presume the facts set forth by the state courts are correct. 28 U.S.C. § 2254(e)(1). The Indiana Court of Appeals set forth the facts underlying Mr. Varner’s conviction as follows: Varner killed [Danielle] Brown in Lake County using a Draco firearm. The gun was capable of firing the same ammunition as an AK-47 rifle and could penetrate police body armor. After the killing, Varner fled the scene and was driving in Benton County when he failed to make a complete stop at a stop sign. Benton County Sheriff’s Department Deputy Paden Clements began following Varner’s vehicle, which quickly pulled into a gas station and parked at a gas pump. When Deputy Clements pulled in behind Varner’s vehicle and opened the door of his marked police vehicle, Varner drove away from the gas station and ran a red light. Deputy Clements activated his emergency lights and pursued Varner at speeds approaching approximately 100 miles per hour.

During the pursuit, Deputy Clements observed Varner reaching into the passenger side of his vehicle. Varner then raised his arm over the headrest, pointing backward toward Deputy Clements’ vehicle. Deputy Clements heard gunshots and saw Varner’s back window explode outward. Deputy Clements also heard bullets “whizzing” past his vehicle and described the sound as “very close.”

The gunfire cause[d] Deputy Clements to swerve his vehicle and make a “hard turn” over a concrete barrier before he could renew his pursuit. The chase moved from the highway onto county roads. When Deputy Clements temporarily lost sight of Varner’s vehicle around some turns, Varner threw the gun from his vehicle onto the road. As Deputy Clements navigated the turns, he discovered Varner’s vehicle wrecked in a ditch. Varner had fled on foot, but other responding officers soon apprehended him nearby. When Deputy Clements retraced the pursuit route, he recovered the gun that Varner had thrown into the road. Shell casings fired from that weapon were found inside Varner’s vehicle.

The State charged Varner with attempted murder, attempted aggravated battery, possession of a firearm by a serious violent felon, criminal recklessness, and reckless driving. The State also alleged that two firearm sentencing enhancements and a habitual offender enhancement applied.

Varner, who represented himself at trial,1 admitted to the jury that he fired the shots but claimed he did not intend to kill or injure Deputy Clements. The jury acquitted Varner of attempted murder and reckless driving but found him guilty of attempted aggravated battery, possession of a firearm by a serious violent felon, and criminal recklessness. The jury also determined that Varner was a habitual offender and that the two firearms sentencing enhancements applied. At sentencing, the trial court vacated the criminal recklessness conviction and one firearm enhancement based on double jeopardy concerns, and ultimately imposed an aggregate sentence of 61 years.

[ECF 16-6 at 2-4 (internal citations omitted).]

1 The record reflects that Mr. Varner previously represented himself at trial in two other criminal cases, including the related murder case. [See ECF 15-5 at 18-28.] Mr. Varner also opted to represent himself on appeal. [Id. at 4.] In his brief, he raised a variety of claims.2 [ECF 16 at 3.] As is relevant here, he argued that (1) the trial

court erred in refusing to dismiss the charges on double jeopardy grounds; and (2) the state failed to prove beyond a reasonable doubt that he committed attempted aggravated battery. [ECF 16-3 at 3, 4.] The court found his double jeopardy claim waived for failing to make a cogent argument pursuant to Ind. App. Rule 46(A)(8)(a). [ECF 16-6 at 9–10.] The court also rejected his sufficiency of the evidence claim, finding the evidence sufficient to support the conviction. [Id. at 16-17.]

He then petitioned for transfer to the Indiana Supreme Court asserting two claims that he cast as follows: (1) “Did the continuing crime doctrine survive the Supreme Court’s adoption of a new substantive double jeopardy test in Wadle v. State, 151 N.E. 3d 227 (Ind. 2020), and if so, does the three-part test found in Wadle, the actual evidence test found in Richardson v. State, 717 N.E. 2d 32 (Ind. 1999), or a separately enforceable double

jeopardy standard apply to such claims?” and (2) “Are the Supreme Court’s statements in Wadle v. State, 151 N.E. 3d 227, 249 (Ind. 2020) (“if the facts show only a single continuous crime, and one statutory offense is included in the other, then the prosecutor may charge these offenses only as alternative (rather than as cumulative) sanctions”)

2 The Indiana Court of Appeals summarized his claims as follows: “I. Whether Varner is entitled to discharge under Indiana Criminal Rule 4(B)? II. Whether the trial court properly refused to dismiss charges against Varner? III. Whether the trial court abused its discretion and showed bias toward Varner in admitting in his Benton County trial evidence of his testimony in the Lake County murder trial? IV. Whether the trial court abused its discretion in rejecting Varner’s proffered instruction on the continuing crime doctrine? V. Whether the State proved beyond a reasonable doubt Varner’s commission of aggravated battery? VI. Whether alleged irregularities in the habitual offender proceeding justify reversal?” [ECF 16-6 at 4.] judicial dicta that should be given effect as a holding by the Supreme Court?” [ECF 16-8 at 2.] The Indiana Supreme Court denied his petition to transfer without comment. [ECF

16-9.] He then filed his federal petition asserting two claims: (1) there was insufficient evidence to support his attempted aggravated battery conviction; and (2) his conviction for possession of a firearm by a serious violent felon violated double jeopardy principles. [ECF 1 at 3.] The respondent argues that claim one is procedurally defaulted and without merit under governing standards, and claim two is procedurally defaulted and, to the

extent it is based on state law, not cognizable on federal habeas review. [ECF 16.] Mr. Varner filed a traverse in support of his petition. [ECF 20.] ANALYSIS The petition is governed by the provisions of the Anti-Terrorism and Effective Death Penalty Act of 1996 (AEDPA), which allows a court to issue a writ of habeas corpus

“only on the ground that [the petitioner] is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2254(a). Habeas corpus was intended as a “guard against extreme malfunctions in the state criminal justice systems, not a substitute for ordinary error correction through appeal.” Gilbreath v. Winkleski, 21 F.4th 965, 981 (7th Cir. 2021) (citation and quotations omitted). The court can grant an

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