Billy Brantley, Appellant (defendant Below) v. State of Indiana, Appellee (plaintiff Below).

Summary

The Indiana Supreme Court held that voluntary manslaughter may be charged as a standalone offense and that sudden heat is a mitigating factor rather than an element, although some evidence of sudden heat must exist before the jury may consider it. The court found sufficient evidence for the jury to consider both sudden heat and self-defense, held that any instructional error was invited because Brantley approved the instructions, and affirmed his conviction. The court vacated the intermediate appellate decision after granting transfer.