COA issues new opinion in bail case involving self-defense claim

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The Indiana Court of Appeals has issued a new opinion in its decision involving a man charged with murder who sought to be released on bail, but was denied. The judges again held that James Satterfield should be allowed to present evidence of self-defense at a new bail hearing.

Satterfield was charged with murder after shooting and killing Andre Brown, a 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 and open the car 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 after he was charged with felony murder. He claimed he shot Brown in self-defense, but the judge denied his motion.

In its April 16 opinion, the COA determined that even though Satterfield forfeited his right to appeal when he did not timely file a notice of appeal, the appeals court still considered his matter in light of In the Matter of Adoption of O.R., 16 N.E.3d 965, 971 (Ind. 2014). The panel of Judges Patricia Riley, Edward Najam and Cale Bradford held based on Fry v. State, 990 N.E.2d 429, 435 (Ind. 2013), Satterfield should be allowed to present any evidence alluding to possible self-defense.

Tuesday’s opinion in James Satterfield v. State of Indiana, 49A02-1409-CR-659, consisting of Riley, Bradford and Judge Melissa May, also reached the same conclusion.

The docket for this case does not say why the Court of Appeals decided on its own motion to recall and vacate the April 16 opinion and issue a new decision.

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