TROTTER v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] A jury found Corey L. Trotter guilty of battery by means of a deadly weapon, a Level 5 felony, and Trotter admitted to being a habitual offender. On appeal, Trotter argues that the State failed to present sufficient evidence to rebut his self-defense claim. We affirm.

Facts and Procedural History

[2] The facts most favorable to the jury's verdict are as follows. On the night of January 4, 2025, Trotter and his fiancée, Lisa Robinson, were socializing in a home with the homeowner's caretaker, Deana Shumaker. Trotter, Robinson, and Shumaker were in one room. Shumaker's son, Jessie Stephens; the homeowner's granddaughter, Carol Decker; and Decker's husband, Joseph Kloss, were in another room. At some point, Trotter and Robinson “pulled out a bottle of liquor[,]” and Trotter's behavior changed. Tr. Vol. 2 at 119. “He started becoming agitated, aggravated, wanting to pick at [Robinson], trying to pick a fight.” Id. Shumaker asked Trotter “to please calm down and be cool. He would calm down for a little bit, but then it would start again.” Id.

[3] Trotter was also “fooling around with a knife, ․ sharpening it, playing with it.” Id. at 120. Eventually, Shumaker asked Trotter to leave the home. Trotter replied, “[B]***h, I'd stab you.” Id. Stephens entered the room and told Trotter, “[Y]ou're not stabbing my mom.” Id. Trotter and Stephens then “both just started fighting ․ simultaneously.” Id. They wrestled and “toppled onto the couch.” Id. At one point, they “bec[a]me separated[,]” and Shumaker could see “[b]lood running off [Stephens's] head, down onto his face.” Id. at 121.

[4] Decker entered the room and tried to break up the fight. Trotter pushed her “out of the way.” Id. at 154. Kloss saw this and tackled the much smaller Trotter “into the TV stand[.]” Id. at 155. Kloss landed on top of Trotter. The two men started hitting each other, and Kloss “felt something burning ․ [o]n the lower part of [his] stomach.” Id. at 155-56. Kloss looked down and saw that he had been cut. Kloss saw a knife in Trotter's hand, so he pushed that hand “as far away” from him as he could. Id. at 156. Shumaker called 911. Kloss held Trotter down until police officers arrived approximately five minutes later. The officers told Kloss to let Trotter go. Kloss told them that he “wasn't going to let [Trotter] go until [Trotter] let the knife go.” Id. at 157. Trotter dropped the knife, and Kloss “got up off of him[.]” Id.

[5] Both Stephens and Kloss were taken to the hospital. Stephens had “a gash on the side of his head, a couple of lacerations on his forearm, [and] a slice across the bridge of his nose.” Id. at 122. Kloss received eighteen stitches “on [the] lower part of [his] stomach.” Id. at 157. A nurse told Kloss that if he “wasn't a bigger guy, that [Trotter] would have cut [him] clear through to [his] organs.” Id. at 176. Trotter suffered only a “scrape” on his “right arm.” Id. at 190.

[6] The State charged Trotter with two counts of Level 5 felony battery by means of a deadly weapon—one as to Stephens and one as to Kloss—and one count of Level 5 felony intimidation against Shumaker. The State also alleged that Trotter was a habitual offender. A trial was held in May 2025, and the jury was instructed on self-defense using deadly force. Id. at 219. The jury found Trotter guilty of battering Stephens and acquitted him of battering Kloss and intimidating Shumaker. Trotter admitted to being a habitual offender, and the trial court sentenced him to four years executed. This appeal ensued.

Discussion and Decision

[7] Trotter asserts that the State failed to present sufficient evidence to rebut his self-defense claim. “Self-defense is a legal justification for an otherwise criminal act.” Stewart v. State, 167 N.E.3d 367, 376 (Ind. Ct. App. 2021), trans. denied. “The standard of review for a challenge to the sufficiency of the evidence to rebut a claim of self-defense is the same as the standard for any sufficiency of the evidence claim.” Id. “When analyzing a claim of insufficient evidence to support a conviction, we must consider only the probative evidence and reasonable inferences supporting the judgment.” Id. It is the role of the factfinder, not that of an appellate court, to assess witness credibility and weigh the evidence to determine if it is sufficient to support a conviction. Id. “The evidence does not have to overcome every reasonable hypothesis of innocence, and it is sufficient if an inference may reasonably be drawn to support the conviction.” Id.

[8] “The self-defense statute provides that an individual has the right to use ‘reasonable force against any other person to protect the person or a third person from what the person reasonably believes to be the imminent use of unlawful force.’ ” Id. (quoting Ind. Code § 35-41-3-2(c)). “A person is justified in using deadly force, and does not have a duty to retreat, if the person reasonably believes such force is necessary to prevent serious bodily injury to himself or a third person, or to prevent the commission of a forcible felony.” Id. (citing I.C. § 35-41-3-2(c)(1), -(2)). To prevail in presenting a self-defense claim, the defendant must show that he was in a place where he had a right to be, did not provoke, instigate, or participate willingly in the violence, and had a reasonable fear of death or great bodily harm. Id.

[9] “When the defendant raises a self-defense claim which finds support in the evidence, the State carries the burden of negating at least one of the necessary elements.” Id. “The State may meet its 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.” Id. “Whether the State has met its burden is a question of fact for the jury. If a defendant is convicted despite his claim of self-defense, an appellate court will reverse only if no reasonable person could say that self-defense was negated by the State beyond a reasonable doubt.” Id.

[10] Trotter asserts that the State failed to rebut his self-defense claim beyond a reasonable doubt because he was “attacked by two other grown men, both of [whom were] taller and larger than him, one of [whom] was significantly larger than him[,]” i.e., Kloss. Appellant's Br. at 10. But this assertion disregards Shumaker's testimony that Stephens and Kloss (both of whom were unarmed) did not fight against Trotter “at the same time” and that Stephens and Trotter attacked each other “simultaneously[,]” i.e., that Trotter participated willingly in the violence. Tr. Vol. 2 at 127, 120. We must decline Trotter's invitation to reassess witness credibility and reweigh the evidence in his favor, and we conclude that the State rebutted his self-defense claim beyond a reasonable doubt. Accordingly, we affirm Trotter's battery conviction.

[11] Affirmed.

Bailey, Judge.

Tavitas, C.J., and Kenworthy, J., concur.