Curtis Williams, Appellant/Defendant v. State of Indiana, Appellee/Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Early in the morning of February 4, 2023, Curtis Williams walked into an Indianapolis food mart, approached Kenzel Bones, and shot him four times (twice in the head), killing him. A jury found Williams guilty of Level 2 felony voluntary manslaughter, and the trial court sentenced him to thirty years of incarceration with five suspended to probation. Williams contends that the State produced insufficient evidence to rebut his claim that he had been acting in self-defense when he shot Bones. Because we disagree, we affirm.

Facts and Procedural History

[2] Prior to the night of February 3, 2023, there had been “bad blood” between Williams and Bones after Williams had fought with one of Bones's friends. Tr. Vol. IV p. 174. On the night of February 3, 2023, Bones was on a date with his girlfriend, and they had gone to various locations before arriving at an Indianapolis food mart at around 12:30 a.m. on February 4. Bones entered the store.

[3] While Bones was at the register purchasing a drink, Williams, who had left his car running outside, entered the store with a handgun in his hand, which he appeared to be attempting to conceal under his jacket. Bones was holding his drink with both hands as he walked away from the counter and did not appear to recognize Williams as he approached from the side. Williams approached Bones and shot him four times at close range—twice in the head and twice in the neck—killing him. Responding police found a handgun in Bones's pocket, but he had never drawn it.

[4] On February 20, 2023, the State charged Williams with murder and Level 5 felony possession of a machine gun. On February 3, 2025, the State dismissed the machine-gun charge, and Williams's jury trial ended in a mistrial. Between March 10 and 12, 2025, another jury trial was held, after which the jury found Williams not guilty of murder but guilty of the lesser offense of voluntary manslaughter. On May 1, 2025, the trial court sentenced Williams to thirty years of incarceration with five years suspended to probation.

Discussion and Decision

[5] Williams contends that the State produced insufficient evidence to rebut his claim that he had shot Bones in self-defense. “[S]elf-defense is legal justification for an otherwise criminal act.” Gammons v. State, 148 N.E.3d 301, 304 (Ind. 2020). “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.’ ” Stewart v. State, 167 N.E.3d 367, 376 (Ind. Ct. App. 2021) (quoting Ind. Code § 35-41-3-2(c)), trans. denied. Additionally, 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 to a third person. Ind. Code § 35-41-3-2(c)(1), -2(c)(2). To prevail on a claim of self–defense involving the use of deadly force, the defendant must show that: (1) he was in a place where he had a right to be; (2) he did not provoke, instigate, or participate willingly in the violence; and (3) he had a reasonable fear of death or great bodily harm. Wilson v. State, 770 N.E.2d 799, 800 (Ind. 2002).

[6] When a 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.” Hughes v. State, 153 N.E.3d 354, 361 (Ind. Ct. App. 2020), trans. denied. “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). 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.” Wilson, 770 N.E.2d at 800–01. We conclude that this is not one of those cases.

[7] For one thing, the jury was entitled to conclude that Williams had not acted without fault. Williams left his car running and entered the store with his gun drawn and concealed, supporting a reasonable inference that he was prepared (and expecting) to use it to kill Bones. When Williams did use the gun seconds later, he shot Bones four times, killing him. If Williams, as he testified, was fearful for his life and had not even known that Bones was there, he could have easily left the store without further incident, because it is apparent from the video footage that Bones had not even seen him. Because the evidence supports a reasonable inference that Williams was the initial, and only, aggressor, the jury was entitled to find that he had not acted without fault. See, e.g., Jones v. State, 491 N.E.2d 999, 1000 (Ind. 1986) (concluding that a self-defense claim was invalid when evidence showed that the defendant had been the initial aggressor).

[8] The jury was also entitled to find that Williams had not been in reasonable fear or apprehension of death or great bodily harm. Surveillance video shows Bones holding a soft drink with both hands, not a firearm, and, while Williams testified that he thought that he and Bones had “locked eyes” and that Bones might have been reaching for a gun, these claims find no support in the surveillance footage. Tr. Vol. IV p. 172. Far from doing anything threatening to Williams, Bones does not even seem to have been aware of Williams's presence before the shooting. As for Williams's testimony that he feared for his life because of threats made by Bones, the jury was under no obligation to credit Williams's claim of being “scared” and did not. Tr. Vol. IV. p. 172; see, e.g., McCullough v. State, 985 N.E.2d 1135, 1139 (Ind. Ct. App. 2013) (providing that the jury, acting as the trier of fact, was under no obligation to credit defendant's statement to police that he had acted without fault or that his actions had been reasonable), trans. denied; see also Brooks v. State, 683 N.E.2d 574, 577 (Ind. 1997) (affirming murder conviction over defendant's claim that the victim had been reaching for a gun where no witness had testified that the victim had had a gun and one had testified that the defendant had “put the gun to the back of [the victim's] head and shot him”). Williams has failed to establish that the State produced insufficient evidence to rebut his claim of self-defense.

[9] We affirm the judgment of the trial court.

Bradford, Judge.

Pyle, J., and Kenworthy, J., concur.