Tramell L. White, Appellant/Defendant v. State of Indiana, Appellee/Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] In October of 2024, Tramell White and Rosendo Caraballo were both inmates in the Benton County jail when White became upset with Caraballo and punched him in the head approximately ten times. Caraballo was put on a ventilator and holes were drilled into his skull to relieve pressure on his brain caused by bleeding. The State charged White with Level 3 felony aggravated battery; a jury found him guilty; and, after White admitted that he was a habitual offender, the trial court sentenced him to twenty-five years of incarceration with two years suspended to probation. White contends that the State produced insufficient evidence to sustain his conviction. We affirm.

Facts and Procedural History

[2] On October 30, 2024, White and Caraballo were both inmates in the Benton County jail in a pod that shared a common area. At around 6:00 a.m., Caraballo was in the common area watching music videos on television when White became upset about the channel Caraballo was watching. White expressed his displeasure and pulled his socks over his pants, which indicated that he was preparing to fight. White punched Caraballo in the face, knocking him down and causing him to briefly lose consciousness. While Caraballo was on the ground, White punched him in the face approximately ten more times.

[3] After being taken to a hospital in Lafayette, Caraballo underwent endotracheal intubation and was placed on a ventilator, which is a procedure typically done when a patient is unable to breathe on his own. Caraballo also underwent a decompressive craniotomy due to epidural hematoma, in which holes are drilled through a person's skull to relieve pressure on the brain, performed “in circumstances where someone is at threat of life” and the condition is “potentially life-threatening.” Tr. Vol. II p. 216. The complexity of Caraballo's injury and the risk of complication and death was high because of the emergent surgery, life-threatening nature of the injury, and respiratory failure. After his condition was stabilized in Lafayette, Caraballo was airlifted to a Level 1 trauma center in Indianapolis, which is the “highest degree of trauma center[,]” where he remained on a ventilator. Tr. Vol. II p. 216. All told, Caraballo had suffered a right temporal bone fracture, epidural hematoma, zygomatic arch fracture, maxillary sinus fracture, and orbital floor fracture.

[4] On November 21, 2024, the State charged White with Level 3 felony aggravated battery and alleged that he was a habitual offender. White's trial was held on March 11, 2025. Dr. Andrew Drahos, who treated Caraballo after he was airlifted to Indianapolis, testified that an epidural hematoma can cause an altered level of consciousness, respiratory failure, and death and the epidural hematoma Carabello had suffered had been large, and if it had been untreated, had carried a substantial risk of death. Dr. Drahos indicated that, even with treatment, the epidural hematoma could have bled again and caused additional brain damage and other complications, which could have developed and progressed to brain death. A jury found White guilty of Level 3 felony aggravated battery, and he admitted to being a habitual offender. On April 15, 2025, the trial court sentenced White to fifteen years of incarceration for aggravated battery, enhanced his sentence ten years by virtue of his status as a habitual offender, and suspended two years to probation.

Discussion and Decision

[5] White contends that the State failed to produce sufficient evidence to sustain his conviction for Level 3 felony aggravated battery, specifically that the State failed to produce sufficient evidence that he inflicted injury creating a substantial risk of death. When reviewing the sufficiency of the evidence, we neither reweigh the evidence nor reevaluate the credibility of witnesses. Suggs v. State, 51 N.E.3d 1190, 1193 (Ind. 2016). “All probative evidence, even where it might be conflicting, and the reasonable inferences to be drawn from that evidence are viewed in the light most favorable to the judgment of conviction.” C.S. v. State, 8 N.E.3d 668, 679 (Ind. 2014). “[A]ppellate courts must affirm if the probative evidence and reasonable inferences drawn from that evidence could have allowed a reasonable trier of fact to find the defendant guilty beyond a reasonable doubt.” Drane v. State, 867 N.E.2d 144, 147 n.4 (Ind. 2007) (citation and quotation marks omitted; emphasis in original). Reversal is warranted only if the defendant can show that no reasonable fact-finder could have found him guilty on the evidence in the record. McAlpin v. State, 80 N.E.3d 157, 161 (Ind. 2017).

[6] In order to convict White of Level 3 felony aggravated battery, the State was required to establish that he “knowingly or intentionally inflict[ed] injury on a person that create[d] a substantial risk of death[.]” Ind. Code § 35-42-2-1.5. White contends only that the State failed to establish a substantial risk of death. When determining whether an injury creates a substantial risk of death, we “look to observable facts, including the nature and location of the injury, and the treatment provided.” Alexander v. State, 13 N.E.3d 917, 921 (Ind. Ct. App. 2014) (citing Oeth v. State, 775 N.E.2d 696, 702 (Ind. Ct. App. 2002), trans. denied). Whether there is a substantial risk of death is a question for the factfinder, and a jury may rely on its collective common sense and knowledge acquired through everyday experiences in making its determination. Young v. State, 725 N.E.2d 78, 82 (Ind. 2000).

[7] We have little hesitation in concluding that the State produced sufficient evidence to allow a finding that White had inflicted injuries on Caraballo that had created a substantial risk of death. After White's beating, Caraballo was transported to the hospital, where he was placed on a ventilator (likely because he could not breathe on his own) and had holes drilled in his skull to relieve pressure on his brain. Dr. Drahos testified that the risk of complication and death was high because Carballo had suffered a traumatic brain injury that required emergent surgery, involved respiratory failure, and was life-threatening in nature. This evidence amply supports the jury's verdict. See Oeth, 775 N.E.2d at 702 (concluding that evidence was sufficient to establish substantial risk of death when victim had been struck on head and lost consciousness for period of time and the injury had caused profuse bleeding and required nine stitches). White's arguments to the contrary are nothing more than an invitation to reweigh the evidence, which we will not do. Drane, 867 N.E.2d at 146.

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

Bradford, Judge.

Tavitas, C.J., and Felix, J., concur.