Michael Owens, Appellant/Defendant v. State of Indiana, Appellee/Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] On September 11, 2023, Keontae Walls-Leonard and his two brothers were driving in Indianapolis when they saw Michael Owens, who owed Walls-Leonard seventy-five dollars. Walls-Leonard pulled over and spoke to Owens about the money, and, after he had asked for it a second time, Owens pulled out a handgun and shot Walls-Leonard multiple times, killing him. The State charged Owens with murder, and, after a jury found him guilty, the trial court sentenced him to sixty years of incarceration. Owens contends that the State produced insufficient evidence to rebut his claim that he had killed Walls-Leonard in self-defense. Because we disagree, we affirm.

Facts and Procedural History

[2] On September 11, 2023, Walls-Leonard and his brothers Damorion Walker and Kamori Walls were driving to a park on the east side of Indianapolis to play basketball. None of the three was armed. On the way, Walls-Leonard, Walker, and Walls saw Owens walking by the Pangea Apartments. Tr. Vol. II p. 109. Walls-Leonard pulled into the complex and began speaking with Owens. As it happened, Owens owed Walls-Leonard seventy-five dollars. Owens walked up to the front passenger window, next to where Walker was seated.

[3] Walls-Leonard spoke with Owens and asked for his money. While both Walls-Leonard and Owens were swearing, it was “a buddy-buddy type of cussing [and] they [were] cool with each other.” Tr. Vol. II p. 155. After Walls-Leonard, who had both hands on the steering wheel, asked about the money a second time, Owens reached down, said “I've got your money right here[,]” pulled out a handgun, and began shooting. Tr. Vol. II p. 135. Owens shot Walls-Leonard around eight to ten times, killing him.

[4] On September 19, 2023, the State charged Owens with murder and Level 5 felony unlawful possession of a firearm. On August 7, 2025, the trial court granted the State's motion to dismiss the unlawful-possession charge. On August 7, 2025, Owens filed a notice of intent to claim self-defense. On August 11, 2025, Owens's jury trial began, after which the jury found him guilty of murder. On September 5, 2025, the trial court sentenced Owens to sixty years of incarceration.

Discussion and Decision

[5] Owens contends that the State produced insufficient evidence to rebut his claim that he had shot Walls-Leonard in self-defense. “A valid claim of self-defense is legal justification for an otherwise criminal act.” Gammons v. State, 148 N.E.3d 301, 304 (Ind. 2020) (citation and quotations marks omitted). “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. 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] “Once a defendant raises a claim of self-defense, the State has 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 upon 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 jury.” Id.

[7] 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. Sanders v. State, 704 N.E.2d 119, 123 (Ind. 1999). We neither reweigh the evidence nor judge the credibility of witnesses. Id. If there is sufficient evidence of probative value to support the conclusion of the trier of fact, then the verdict will not be disturbed. Id. If a defendant is convicted despite his claim of self-defense, we 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. In this case, the verdict will not be disturbed.

[8] First, the evidence supports a finding that Owens initiated the violence. As mentioned, Walker testified that, although they had both been swearing, Owens and Walls-Leonard had been “cool with each other.” Tr. Vol. II p. 155. Walker also testified that, when Walls-Leonard (whose hands had been on the steering wheel) had asked Owens a second time about his debt, Owens had pulled a gun and started shooting. The evidence most favorable to the jury's verdict indicates that Owens was the person who had instigated the violence, and this was sufficient to negate his claim of self-defense. See, e.g., Ervin v. State, 114 N.E.3d 888, 896 (Ind. Ct. App. 2018) (“[W]e can unequivocally say the State met its burden to overcome Ervin's claims [of self-defense] because Ervin had no right to block traffic and Ervin instigated the situation.”), trans. denied.

[9] Second, the evidence most favorable to the jury's verdict supports a finding that, even if Owens had had a fear of death or great bodily harm that day, it had not been a reasonable one. The State presented evidence that Walls-Leonard had not been armed that day and had kept his hands on the wheel throughout his conversation with Owens, and the record also indicates that neither Walls nor Walker had been armed, either. Moreover, while the conversation between Owens and Walls-Leonard had involved swearing, it had been “a buddy-buddy type of cussing [and] they [were] cool with each other.” Tr. Vol. II p. 155.

[10] Owens points to his testimony that he believed that he had seen a firearm in Walls-Leonard's lap and argues that other evidence allegedly establishes that Walls-Leonard had normally carried a firearm, Walker and Walls had hidden evidence that Walls-Leonard had been armed the day of the shooting, Walls-Leonard and Owens had been involved in a heated conversation, and the shooting had taken place in a “high crime” area. Appellant's Br. p. 9. First, any assertion that Walls-Leonard had normally carried a firearm or suggestion that Walker and Walls had hidden evidence is speculative. The record establishes—at most—that Walls-Leonard had owned a firearm and that Walker and Walls had, perhaps, had the opportunity to conceal evidence, nothing more. As for evidence regarding the contentious nature of Owens's and Walls-Leonard's conversation and whether the area was “high crime,” the evidence is conflicting, with testimony that the conversation was “buddy-buddy” and that the area was not high-crime. In any event, the jury was under no obligation to credit any of the evidence Owens cites or to draw the same speculative inferences and apparently did not. 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); 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 witness had testified that the defendant had “put the gun to the back of [the victim's] head and shot him”). In the end, Owens's argument is nothing more than an invitation to reweigh the evidence, which we will not do. See, e.g., Sanders, 704 N.E.2d at

123. Owens has failed to establish that the State produced insufficient evidence to rebut his claim of self-defense.

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

Bradford, Judge.

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