Woman loses appeal of murder conviction over self-defense claim

The murder conviction of a woman whose voluntary manslaughter plea was rejected by a judge after the woman insisted she shot a man in self-defense was affirmed on appeal Monday.

Briana Wilson was convicted of the murder of Maurice Martinez and sentenced to 55 years in prison with 10 years suspended. According to the record, Wilson admitted to shooting Martinez twice in the back as he tried to leave her apartment. Wilson said Martinez claimed that either she or her cousin, R.T., who was also at the residence, had stolen money from him, and that Martinez had threatened them.

Wilson had pleaded guilty to voluntary manslaughter with a maximum sentence of 15 years, which the Marion Superior Court took under advisement. At the sentencing hearing, “the trial court expressed concern about whether Wilson had entered her plea knowingly and voluntarily based on her statements” in her presentencing report.

Called to the stand, the state asked on cross-examination, “You understand that you did not shoot Mr. Martinez in self-defense?” Wilson replied, “It was self-defense.”

“He was violating me in my own home and he also violated [R.T.] He touched on her and he threatened to kill me, and he said that I had stole [sic] eighty … dollar[s] from him which I don’t have to steal anything from no one. He pulled on my arm and he said he was going to take me out to his car and shoot me. That’s what he said and I got loose and I went and got my gun and I shot him because he was dragging me out of my house by my arm,” she said on the stand.

Judge Barbara Crawford then rejected the plea agreement and set the case for trial, leading to Wilson’s murder conviction. The Court of Appeals affirmed, first finding the court’s comments and chronological case summary for the guilty plea hearing “are not conclusive as to whether the trial court accepted Wilson’s plea agreement or took it under advisement.”

“We further conclude that, when the trial court made clear at the sentencing hearing that its position was that it had only taken the plea agreement under advisement, Wilson had the affirmative duty to object or otherwise make a record that the plea agreement had in fact already been accepted. Instead, the record on appeal does not show that Wilson did anything other than assent to the trial court’s determination. We therefore conclude that Wilson has not met her burden on appeal to show that the trial court accepted her agreement at the guilty plea hearing,” Judge Edward Najam wrote in Briana Michelle Wilson v. State of Indiana, 19A-CR-1987.

“Wilson next contends that the court abused its discretion when it rejected her plea agreement at the sentencing hearing,” Najam wrote. “Wilson asserts that her comment that she had acted in ‘self-defense’ was not a legal conclusion. She further asserts that her comment also was not a claim of innocence but a plea for leniency. The State, in turn, contests those arguments.

“We need not decide whether Wilson’s statements were attempts at legal conclusions or were claims of innocence. Our standard of review in this appeal is deferential and controls the outcome here,” Najam continued. “The factual basis submitted to the court on the plea agreement could have been found by a jury to establish the offense of murder, a mitigated offense of voluntary manslaughter, or an exculpatory act of self-defense. In such circumstances, it was within the trial court’s discretion to reject the plea agreement and have that call be made by the jury. We therefore cannot say that the trial court abused its discretion when it rejected Wilson’s plea agreement,” Najam wrote.

The COA also rejected Wilson’s claim that the trial court abused its discretion by failing to offer a jury instruction on voluntary manslaughter.

“… (W)e are, at best, left with an uncorroborated — if not contradicted — claim of an attack some time prior to a shooting along with Martinez’s statement that he would return with a gun. Even if under these circumstances the trial court could have given an instruction on voluntary manslaughter, we cannot say that the trial court abused its discretion when it declined to do so.”