Jones v. State
1997 WL 778595, 1997 Ind. LEXIS 218, 689 N.E.2d 722 (1997)
Rule of Law:
Intent to kill may be inferred from the use of a deadly weapon in a manner likely to cause death or serious bodily injury, and a verdict of murder based on 'knowing' conduct is legally consistent with an acquittal for attempted murder, which requires specific intent.
Facts:
- Jones and his friend walked to a home on Spatz Avenue shortly after midnight, where 15 to 20 people were socializing inside.
- Jones was carrying a nine-millimeter semiautomatic handgun.
- While his friend waited in the back, Jones approached the front of the house.
- Jones fired at least four shots in rapid succession into the window and open door of the residence.
- The gunfire struck and killed Troy Williams and injured Latrail Gamble.
- Jones fled the scene immediately after the shooting.
- The day after the event, Jones admitted to friends that he fired the shots because he was tired of rival gang members killing his friends.
Procedural Posture:
- The State of Indiana charged Jones with murder and attempted murder in the trial court.
- A jury found Jones guilty of murder.
- The jury found Jones not guilty of attempted murder.
- The trial court sentenced Jones to sixty-five years in prison.
- Jones filed a direct appeal to the Supreme Court of Indiana.
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Issue:
1. Is there sufficient evidence of intent to support a murder conviction when a defendant fires multiple shots into a crowd without explicitly stating an intent to kill? 2. Are jury verdicts legally inconsistent when they convict a defendant of murder regarding one victim but acquit him of attempted murder regarding a second victim arising from the same rapid gunfire?
Opinions:
Majority - Shepard
Yes, the evidence was sufficient to prove intent, and the verdicts are consistent. On the issue of intent, the Court reasoned that intent to kill can be inferred from the intentional use of a deadly weapon in a manner likely to cause death or serious injury. Firing a handgun four times into a crowded room clearly meets this standard. Regarding the consistency of the verdicts, the Court explained that attempted murder requires 'specific intent' to kill. However, murder can be proven if the defendant acted 'knowingly' (being aware of a high probability that death would result). Therefore, it was logically consistent for the jury to find Jones acted 'knowingly' regarding the death (supporting the murder conviction) but lacked the 'specific intent' required for the attempted murder charge regarding the survivor. Additionally, the Court acted sua sponte to correct a sentencing error, noting that the trial court applied a sentencing statute that was not yet effective when the crime was committed, violating ex post facto principles.
Analysis:
This case highlights the critical mens rea distinction between murder and attempted murder in Indiana law. It clarifies that while attempted murder necessitates a finding of specific intent, a murder conviction can be sustained on the slightly lower 'knowing' standard—defined as awareness of a high probability of death. This distinction allows courts to uphold seemingly contradictory jury verdicts where a defendant is convicted of the completed crime against one victim but acquitted of the attempt against another in the same transaction. Furthermore, the decision reinforces the fundamental principle that criminal defendants must be sentenced according to the statutes in effect at the time of the offense, not the time of sentencing.
