Jeff A. Large, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2025)

MEMORANDUM DECISION

Case Summary

[1] Jeff Large appeals his conviction for Class A misdemeanor battery resulting in bodily injury.¹ He raises one issue for review: Did the State present sufficient evidence to rebut his claim of self-defense? We affirm.

Facts and Procedural History

[2] In 2022, John Frey was temporarily living at his girlfriend Nancy's house. Nancy had hired Large to do electrical repairs at the property. She previously employed Large to install an electric vehicle charger in the garage—and Frey believed Large had done a shoddy job. On the afternoon of February 22, 2022, Frey entered the house and sat down “in a low chair with [his] feet up on an ottoman” in the family room. Tr. Vol. 2 at 56. Large was “working around the house[.]” Id. at 76.

[3] Some time after Frey's arrival, his girlfriend notified him she would soon be coming home. Frey asked Large how long it would be until he completed the electrical work. When Large did not provide a definitive answer, Frey commented Large should “button up” the job as he had “been [there] all day” and had “plenty of time” to get it done. Id. at 55. Frey remarked he should get “one of [his] guys” to come and finish the job instead. Id. According to Frey, Large “got belligerent” then “stormed across the room” and stood next to where Frey was sitting. Id. at 55–56.

[4] With Large “right above” him, Frey told Large to “step back” or else he “better expect some result[.]” Id. at 56. Frey stood up and demanded Large leave. Frey walked out of the family room and headed to the garage. Large followed behind. As Frey was moving between rooms in the house, Large “sucker punched” him from behind on the temple. Id. at 57–58. Large was holding a screwdriver, and “he came through a second time with a downward stroke to stab [Frey] in the shoulder.” Id. at 66. Upon turning around, Frey shoved Large. The two argued verbally, and Frey ordered Large to continue walking in front of him to the garage. Once there, Large attempted to hit Frey again but missed. Frey warned Large he would call the police; Large got in his car and drove away. Frey called 9-1-1 and recounted the incident to the responding officer. Large never reached out to law enforcement.

[5] Frey had “a melon spot ․ on the side of [his] head[.]” Id. at 64. He also had a bloody lip and lacerations to his chest. A few hours after the confrontation, he discovered “a hole in [his] shoulder” where Large had apparently “pierced [him]” with the screwdriver. Id. at 66.

[6] The State charged Large with battery resulting in bodily injury, alleging Large knowingly touched Frey in a rude, insolent, or angry manner by striking him, which resulted in bodily injury—pain and lacerations—to Frey. See Appellant's App. Vol. 2 at 17; see also I.C. §§ 35-42-2-1(c)(1), (d)(1). At the bench trial, Large and Frey testified about the altercation. In his testimony, Large painted Frey as the aggressor, arguing he acted in self-defense. Large described Frey as “demeaning” and “disrespectful” toward him and testified Frey threatened to “rip [his] head off and shit down [his] neck.” Tr. Vol. 2 at 91. He claimed Frey attacked him from behind and he feared for his life. Large attributed Frey's injuries to a fall occurring in the heat of the moment.

[7] The trial court found Large guilty as charged. The court described why it found Frey's version of events convincing:

[T]he evidence I've got leads me to believe that those injuries ․ you've got a busted lip, you've got ․ a spot on the left temple, and you've got a puncture wound ․ on the shoulder. [F]rom everything I can tell, that's quite consistent with the version of events that Mr. Frey offered here today. And not consistent with what Mr. Large has offered or even how a person, I think, would reasonably respond to a situation where they're put in fear of bodily injury or even worse.

Id. at 106.

There was sufficient evidence Large did not act in self-defense.

[8] A valid claim of self-defense is legal justification for an otherwise criminal act. Coleman v. State, 946 N.E.2d 1160, 1165 (Ind. 2011). “The standard of review for a challenge to the sufficiency of evidence to rebut a claim of self-defense is the same as the standard for any sufficiency of the evidence claim.” Wilson v. State, 770 N.E.2d 799, 801 (Ind. 2002). We respect the factfinder's exclusive province to weigh conflicting evidence, Phipps v. State, 90 N.E.3d 1190, 1195 (Ind. 2018), and consider only the probative evidence and reasonable inferences supporting the judgment of the trier of fact, Hall v. State, 177 N.E.3d 1183, 1191 (Ind. 2021). To prevail on a claim of self-defense, a defendant must show: (1) he was in a place where he had a right to be; (2) he acted without fault; and (3) he had a reasonable fear of death or great bodily harm to himself or a third person. Coleman, 946 N.E.2d at 1165.

[9] Once a defendant claims self-defense, the State bears the burden of disproving at least one of these elements beyond a reasonable doubt. Larkin v. State, 173 N.E.3d 662, 670 (Ind. 2021). The State may meet this burden by rebutting the defense directly, by affirmatively showing the defendant did not act in self-defense, or by simply relying on the sufficiency of its evidence in chief. Miller v. State, 720 N.E.2d 696, 700 (Ind. 1999). Whether the State has met its burden is a question of fact for the factfinder. Id. “We will reverse a conviction only if no reasonable person could say the State overcame the self-defense claim beyond a reasonable doubt.” Larkin, 173 N.E.3d at 670.

[10] Here, the State presented sufficient evidence to rebut Large's claim of self-defense. The trier of fact could have rejected Large's testimony depicting Frey as the aggressor and himself without fault. Following the incident, Frey had visible injuries on his lip, temple, chest, and shoulder. Those injuries were consistent with Frey's version of events. At trial, Large offered a conflicting version of the altercation. He attributed Frey's injuries to a fall “against that dog cage” where “he very easily could have hurt his face[.]” Tr. Vol. 2 at 95. But the trial court found Large's testimony not credible. The court specifically referred to Frey's testimony in explaining its judgment, finding his injuries “quite consistent with the version of events that Mr. Frey offered here today.” Id. at 106. In short, Large invites us to reweigh evidence and reassess witness credibility, which we cannot do. See Phipps, 90 N.E.3d at 1195.

Conclusion

[11] The State presented sufficient evidence to rebut Large's claim of self-defense.

[12] Affirmed.

FOOTNOTES

1.   Ind. Code §§ 35-42-2-1(c)(1), (d)(1) (2020).

Kenworthy, Judge.

Bailey, J., and Tavitas, J., concur.