Jarren Duff v. State of Indiana

No. 25A-CR-2787 (Ind. Ct. App. June 22, 2026) · Indiana Court of Appeals · June 22, 2026 · No. 25A-CR-2787

Summary

The Indiana Court of Appeals affirmed Jarren Duff’s convictions for aggravated battery and battery resulting in moderate bodily injury, as well as his aggregate nine-year sentence. The court held that sufficient evidence established serious permanent disfigurement, rejected Duff’s sentencing-discretion challenge, and concluded that the sentence was not inappropriate under Indiana Appellate Rule 7(B).

Holdings

  1. The evidence was sufficient to support Duff's aggravated-battery conviction because the altered bone structure and permanent plates around Dickerson's eye, as well as the permanent damage to his teeth, constituted serious permanent disfigurement even without readily visible scarring.
  2. The trial court did not abuse its discretion in considering Duff's self-defense testimony in assessing the mitigating circumstance that the crime was unlikely to recur, and the record did not show that the court improperly treated Duff's maintenance of innocence as an aggravating or mitigating factor.
  3. Duff's aggregate nine-year sentence was not inappropriate in light of the nature of the offenses and his character.

Questions Presented

  1. Whether sufficient evidence established that Dickerson suffered serious permanent disfigurement supporting Duff's aggravated-battery conviction.
  2. Whether the trial court abused its discretion in considering aggravating and mitigating circumstances and rejecting or evaluating Duff's self-defense testimony during sentencing.
  3. Whether Duff's aggregate sentence was inappropriate in light of the nature of the offense and his character under Indiana Appellate Rule 7(B).

Disposition

affirmed

Cases Cited (24)

  • Hancz-Barron v. State, 235 N.E.3d 1237, 1244 (Ind. 2024)(followed)
  • Sutton v. State, 167 N.E.3d 800, 801 (Ind. Ct. App. 2021)(followed)
  • Drane v. State, 867 N.E.2d 144, 146-47 (Ind. 2007)(followed)
  • Cornelious v. State, 988 N.E.2d 280, 283 (Ind. Ct. App. 2013)(followed)
  • James v. State, 755 N.E.2d 226, 229-30 (Ind. Ct. App. 2001)(followed)
  • Haverstick v. State, 648 N.E.2d 399, 401 (Ind. Ct. App. 1995)(followed)
  • Anglemyer v. State, 868 N.E.2d 482, 490-91 (Ind. 2007), as amended and clarified on reh'g, 875 N.E.2d 218 (Ind. 2007)(followed)
  • Smallwood v. State, 773 N.E.2d 259, 263 (Ind. 2002)(followed)
  • Phipps v. State, 90 N.E.3d 1190, 1197 (Ind. 2018)(followed)
  • Schuler v. State, 132 N.E.3d 903, 904-05 (Ind. 2019)(followed)

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