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Editor's note: The April 16 opinion in this case was withdrawn and a new opinion issued May 12.
A defendant accused of murder must be allowed to present evidence and witnesses at a bail hearing in an endeavor to rebut the state’s burden that the defendant likely committed murder, the Indiana Court of Appeals held Thursday. Since that did not happen in James Satterfield’s case, the judges remanded the matter for further proceedings.
Satterfield was charged with murder after shooting and killing Andre Brown, the friend of the prostitute Satterfield was with at the time of the shooting. Satterfield and Maegan Biddle were in Satterfield’s parked car when he saw a man approach it and open the door Satterfield said he had locked. That man – Brown – was holding a shiny object. Satterfield grabbed his gun and fired one shot that struck Brown. Satterfield is licensed to carry a gun.
He turned himself in after learning of Brown’s death and sought to be released on bail. He claimed he shot Brown in self-defense, but the judge denied his motion.
In James Satterfield v. State of Indiana, 49A02-1409-CR-659, the appeals court determined that even though Satterfield forfeited his right to appeal when he failed to timely file a notice of appeal, based on In the Matter of Adoption of O.R., 16 N.E.3d 965, 971 (Ind. 2014), his case deserved a determination on the merits.
In 2013, the Indiana Supreme Court reversed nearly 150 years of precedent regarding bail in Fry v. State, 990 N.E.2d 429, 435 (Ind. 2013). The justices shifted the burden of proof from the defendant to the state to show that in the murder case either the proof is evident or the presumption is strong that the defendant committed murder.
“In light of this reassessment of the burden of proof in bail hearings, we are called upon today to determine whether a defendant is allowed to present evidence of an affirmative defense to rebut the State’s strong presumption that the defendant more likely than not committed the murder (or treason) accused of,” Judge Patricia Riley wrote.
“While Satterfield answered this issue of first impression in the affirmative and suggests that we should impose on the trial court a requirement to assess a defendant’s justifiable defenses during a bail proceeding, the State maintains that ‘[p]ossible defenses have no bearing on the bail issue.’ We disagree.”
The judges looked at cases dating back to the Civil War for guidance as to the nature of evidence admissible in bail proceedings and reaffirmed a defendant’s right to present exculpatory evidence as to his or her culpability during a bail proceeding and the trial court’s duty to take this evidence into account when considering a request for bail.
Since the trial court refused to weigh any evidentiary facts alluding to possible self-defense, the judges sent the case back to the trial court to conduct a new bail hearing in accordance with this opinion.
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