Overzealous Muscle is a common Creature — Ogre Mercenary card from Outlaws of Thunder Junction (OTJ), collector number 97. Current market price: $0.13 (foil $0.12), TCGplayer market prices via Scryfall.
Whenever you commit a crime during your turn, this creature gains indestructible until end of turn. (Targeting opponents, anything they control, and/or cards in their graveyards is a crime. Damage and effects that say "destroy" don't destroy a creature with indestructible.)