An Indianapolis security guard who shot and killed a woman in her vehicle must remain in jail until his trial, the Indiana Court of Appeals has ruled, affirming the denial of the guard’s petition for release on bail in a “close case.”
Melvin Hall, Natisha Staffney and Danielle Taylor were on duty as security guards at an apartment complex in August 2020 when Naytasia Williams pulled in and parked in the complex’s lot. Williams exited her vehicle and began arguing with two other women.
Though the women were threatening to kill each other, the consensus was that they were just blowing off steam, and Hall did not try to intervene. Williams eventually returned to her vehicle and, according to a passenger, picked up a handgun that was in the driver’s seat and moved it out of the way.
Hall was shining his flashlight into the car at the same time, and when he saw the gun he immediately fired three shots through the passenger window. Williams was struck and later died at a hospital.
Hall was charged with murder but petitioned for release on bail, arguing he had acted in self-defense or sudden heat. The Marion Superior Court denied his petition, finding the state had “met its burden to show by a preponderance of the evidence that the proof is evident or the presumption strong that Hall committed the offense of murder.”
The Indiana Court of Appeals affirmed that denial Wednesday in Melvin Eugene Hall, II v. State of Indiana, 21A-CR-41. The panel agreed with the state that its burden at the bail hearing was to disprove self-defense by a preponderance of the evidence, citing to Fry v. State, 990 N.E.2d 429 (Ind. 2013), and Doroszko v. State, 154 N.E.3d 874 (Ind. Ct. App. 2020), trans. denied.
“We begin by noting that since Fry announced that the burden in a bail hearing in a murder case would be borne by the State rather than the defendant, there have been only two appeals of a trial court’s denial of bail, and neither is helpful to the review required here,” Judge Terry Crone wrote for a unanimous appellate panel. “… Thus, we find ourselves in new territory.
“The evidence at the bail hearing shows that while Williams may have been arguing and making threats, Staffney and (Maurice) Parker both testified that they did not find the women’s argument alarming,” Crone wrote. “Significantly, none of the three security guards present, including Hall, said anything to the women during the argument or did anything to try to stop it or defuse the situation.”
What’s more, Crone continued, Williams did not direct her anger at Hall, and she “loudly proclaimed” multiple times that she did not have bullets. For his part, Hall did not order Williams to put the gun down or stop but instead fired immediately.
“From this evidence, the trial court reasonably could have found that Hall, more likely than not, used deadly force that was not proportionate to the urgency of the situation. Hall’s argument is merely a request to reweigh evidence, which we must decline,” Crone wrote.
Hall also argued that based on the evidence, he likely committed voluntary manslaughter because he was acting in sudden heat. But, Crone wrote, “Hall’s argument ignores the evidence supporting the trial court’s rejection of his argument that he was acting in sudden heat.”
“Although this does appear to be a close case, existence of sudden heat is a classic question of fact to be determined by the factfinder, and our standard of review requires us to consider any conflicting evidence in favor of the trial court’s ruling and precludes us from reweighing the evidence,” the panel concluded. “Given there is evidence to support the trial court’s ruling that the State carried its burden to show by a preponderance of the evidence that Hall committed murder, we cannot say the trial court abused its discretion. Therefore, we affirm the denial of Hall’s petition for release on bail.”