CAUDILL v. STATE (2026)

MEMORANDUM DECISION

Case Summary

[1] Following a bench trial, Aydon Caudill was convicted of domestic battery, a Class A misdemeanor, and possession of paraphernalia, a Class C misdemeanor. Caudill appeals and contends that the State presented insufficient evidence to disprove his claim of defense of property. We disagree and, accordingly, affirm.

Issue

[2] Caudill presents one issue, which we restate as whether the State presented sufficient evidence to disprove his claim of defense of property.

Facts

[3] In June 2025, Caudill and his girlfriend, K.W., were living in a recreational vehicle (“RV”) that was parked at the Shelby County Fairgrounds. Caudill's dog was living with them in the RV. The weather was extremely hot and humid, and the air conditioning in the RV was inoperable. On June 23, 2025, Caudill left the RV to work a night shift, and he left K.W. to care for the dog while he was at work. K.W. went to sleep at a motel for the night and left the dog in a metal crate inside the RV without food or water. When Caudill and K.W. returned to the RV the next day, they found the dog dead.

[4] Caudill became upset and began to argue with K.W., whom he blamed for the dog's death. A neighbor heard the couple arguing and observed Caudill get into his car. K.W. then attempted to get into the passenger seat. According to the neighbor, “it looked like [K.W.] was leaning in to retrieve something out of the car or try to stop [Caudill] from leaving.” Tr. Vol. II pp. 46-47. Caudill then swung at K.W. several times and struck K.W. in the face at least once.

[5] Law enforcement was notified, and Shelby County Sheriff's Deputy Benjamin Hirschauer was among the officers who responded to the call. Deputy Hirschauer saw Caudill driving toward him. When Caudill saw the deputy, he waved at him and stopped. Caudill then spoke with Deputy Hirschauer. Caudill admitted to being extremely upset about the death of the dog. Caudill also stated that, although he knew he was “not supposed to hit women,” he struck K.W. out of anger. Id. at 30. Caudill told the Deputy that his anger had caused him to hit and threaten to kill K.W. Id. K.W. also spoke with the officers and told them that Caudill had hit her in the face. The police took photos of K.W., which depicted marks on her face. Police entered the RV and found drug paraphernalia.

[6] On June 24, 2025, the State charged Caudill with cruelty to an animal, a Class A misdemeanor; domestic battery, a Class A misdemeanor; intimidation, a Class A misdemeanor; and possession of paraphernalia, a Class C misdemeanor. A bench trial was held on November 20, 2025. At the conclusion of the trial, the trial court found Caudill not guilty of cruelty to an animal and intimidation. As to the domestic battery and possession of paraphernalia charges, the trial court found:

Self-defense is certainly at play. I thought about that. But I think it was above and beyond reasonable force to be perfectly honest․ I went back and looked here, [the eyewitness] testified, “I saw, I did see him swing at her several times. I know for sure he hit her one time. Or that he connected one time.” I think the victim's testimony up here, she got a bit cute. Talked about her lip, no it wasn't her lip, it was her tongue. And when she denied any injury at all, I found her, her story to be incredible. So, I'm gonna credit the testimony I heard that, that shows, and I'm gonna find you guilty of domestic battery as a class “A” misdemeanor. Notwithstanding self-defense, I think you used more force than is necessary to, to stop her unlawful entry upon your vehicle. I think you're still mad at her, and you're given an opportunity to exact your, your anger out, I think that's what, exactly what you did. Although I do note, you, you did immediately regret it and cooperated, and that's a sentencing factor, but not a guilt factor. Finally, I do have no trouble finding you did possess paraphernalia.

Tr. Vol. II p. 66 (emphasis added). The trial court then sentenced Caudill to 180 days, with all but four days already served suspended, and one year of probation. Caudill now appeals.

Discussion and Decision

[7] Caudill argues that the State presented insufficient evidence to disprove his claim of defense of property. The statute governing claims of defense of property provides in relevant part that a person “(1) is justified in using reasonable force, including deadly force, against any other person,” and “(2) does not have a duty to retreat,” “if the person reasonably believes that the force is necessary to prevent or terminate the other person's unlawful entry of or attack on the person's dwelling, curtilage, or occupied motor vehicle.” I.C. § 35-41-3-2(d). Accordingly, to establish a defense of property, Caudill was required to prove that he used reasonable force to prevent or terminate K.W.’s unlawful entry of or attack on Caudill's occupied motor vehicle. See Gomez v. State, 56 N.E.3d 697, 702 (Ind. Ct. App. 2016). And any force employed must have been reasonable in light of the urgency of the situation. Id.

[8] Defense of property, like self-defense and the defense of others, is a legal justification for an otherwise criminal act. McBride v. State, 261 N.E.3d 274, 281 (Ind. Ct. App. 2025), reh'g denied. Thus, a claim of defense of property is analogous to a claim of self-defense. Norton v. State, 261 N.E.3d 794, 800 (Ind. Ct. App. 2025), trans. denied. The State bears the burden of disproving such claims, and must disprove at least one element of the defense beyond a reasonable doubt. Gomez, 56 N.E.3d at 702. It is the role of the trier of fact to determine whether a claim has been disproven. Id. The State may disprove such a defense either by affirmatively showing that the defendant did not act in defense of property, or by simply relying on the sufficiency of its evidence in chief. Fuller v. State, 261 N.E.3d 821, 826 (Ind. Ct. App. 2025), trans. denied. If a defendant is convicted despite a claim of defense of property, the court on appeal will reverse only if no reasonable person could say that the defense was negated by the State. Id.

[9] In the present case, the facts most favorable to the trial court's judgment show that Caudill was angry with K.W. because of the death of his dog, which he blamed on K.W. When Caudill began to leave in his car, K.W. tried to get into the passenger seat. A witness saw Caudill “swing at [K.W.] several times,” and saw Caudill hit K.W. “one time.” Tr. Vol. II p. 47. The blow was sufficient to leave physical marks on K.W.’s face. Caudill admitted to the responding officer that he “knew better [than] to do what he did.” Id. at 42. Caudill also told the officer that “his anger overcame him and that's why he hit and threatened to kill [K.W.]” Id. at 30.

[10] Caudill notes that the trial court itself stated, when announcing its decision, “[s]elf-defense [sic] is certainly at play here.” Id. at 66. But this does not mean that the trial court accepted Caudill's claim of defense of property; the court was merely acknowledging that this defense was an issue at trial. Caudill also argues that his use of force was reasonable and that “no reasonable person could say that Caudill used unreasonable force to get [K.W.] out of his vehicle after she entered it unlawfully and refused to get out.” Appellant's Br. p. 9. We disagree. The trial court, as the trier of fact, was within its discretion in finding that punching or striking K.W. in the face was unreasonable under the circumstances. The trial court also reasonably concluded that Caudill struck K.W. out of anger, not to prevent her from entering his vehicle.¹

[11] Caudill's arguments are little more than a request that we consider evidence unfavorable to the trial court's judgment, reweigh the evidence, and come to a conclusion other than that reached by the trial court. This we cannot do. The State presented evidence sufficient to disprove Caudill's claim of defense of property.

Conclusion

[12] Because the State presented evidence sufficient to disprove Caudill's claim of defense of property, we affirm the trial court's judgment.

[13] Affirmed.

FOOTNOTES

1.   In his reply brief, Caudill argues that his emotional state has “no bearing on this case.” Appellant's Reply Br. p. 6. We disagree. Caudill's emotions were relevant to show that he struck K.W. out of anger over the death of his dog, not to prevent her entry into the car. And even if Caudill did strike K.W. to prevent her entry into his car, his anger was relevant to show that he used more force than was reasonable under the circumstances.

Tavitas, Chief Judge.

Weissmann, J., and Foley, J., concur