Aaron L. Fansler v. State of Indiana
2017 Ind. App. LEXIS 321
| Ind. Ct. App. | 2017Background
- Fansler (defendant) accepted an online request from an undercover officer posing as “Kenzie” to meet and sell heroin; he arrived at a hotel room used by law enforcement for the sting.
- Officers arrested Fansler outside the room and brought him inside, where, after Miranda warnings, an officer questioned him and elicited two self-incriminating statements about the location and knowledge of heroin. No electronic recording of that interrogation was produced at trial.
- Law enforcement recovered >7 grams of heroin, multiple pills, a scale, baggies, a syringe, tourniquet, and cash from Fansler’s person/pack.
- Fansler was charged with dealing heroin (Level 3), possession (Level 6), and two misdemeanors; he admitted possession but claimed lack of intent to deliver and asserted entrapment. A jury convicted him on all counts.
- At sentencing the court imposed an enhanced executed 13-year term (10 years executed, 3 suspended) on the dealing count and concurrent shorter terms on other counts; the court found prior criminal history and probation-at-time-of-offense as aggravators and limited mitigators including family hardship and that the sting caused no serious harm.
Issues
| Issue | State's Argument | Fansler's Argument | Held |
|---|---|---|---|
| Admissibility of two post-arrest, post‑Miranda statements under Ind. Evid. R. 617 | Statements admissible because they fall within the routine-booking exception or the hotel room was not a "place of detention" | Statements inadmissible: hotel room was a place of detention and statements were custodial interrogations not electronically recorded; Rule 617 requires exclusion absent an exception | Court: hotel room was a place of detention and booking exception did not apply, but admission was harmless error given other strong evidence of possession and intent to deliver |
| Whether sentencing court abused discretion by not giving significant weight to victim‑induced/facilitated offense as a mitigator | Argued that sting inducement should be a mitigating circumstance; trial court considered it and gave it little weight | Fansler argued the court failed to properly consider or find this statutory mitigator | Court: trial judge considered the mitigator (called it mild) and did not abuse discretion; no remand required |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (Sup. Ct. 1966) (custodial interrogation requires Miranda warnings and recordings are relevant to admissibility rules)
- Maryland v. King, 569 U.S. 435 (Sup. Ct. 2013) (routine booking procedures can justify certain administrative processes like DNA swabs)
- Pennsylvania v. Muniz, 496 U.S. 582 (Sup. Ct. 1990) (routine booking questions exception to Miranda for biographical/administrative information)
- Williams v. State, 43 N.E.3d 578 (Ind. 2015) (standard for reviewing evidentiary rulings and harmless‑error analysis)
- Blount v. State, 22 N.E.3d 559 (Ind. 2014) (harmless‑error test when improperly admitted evidence is supported by independent evidence of guilt)
- Steele v. State, 975 N.E.2d 430 (Ind. Ct. App. 2012) (construing "place of detention" under state law context)
- Scott v. State, 772 N.E.2d 473 (Ind. Ct. App. 2002) (statements minimally probative of intent to deliver may not overcome other evidence)
- Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standards for appellate review of sentencing and when remand is required)