Anderson v. State
2012 Ind. App. LEXIS 38
| Ind. Ct. App. | 2012Background
- Anderson entered Pepper's apartment through a bathroom window and murdered her with multiple stab wounds, also engaging in sexual intercourse with Pepper's body.
- DNA analysis showed sperm and seminal material on Pepper, with DNA matching Anderson at the scene.
- A CODIS DNA match linked Anderson to Pepper's murder months after the crime; a second buccal swab was obtained after arrest.
- Anderson confessed to police after interrogation despite clearly seeking an attorney; the trial court admitted this statement into evidence.
- Anderson was convicted of murder, burglary, and abuse of a corpse, and sentenced to 88 years; on appeal the court reversed the burglary and abuse-of-a-corpse convictions but affirmed the murder sentence, and addressed the DNA evidence under a statutory exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to counsel violated by police questioning | Anderson unequivocally invoked counsel. | Custodial interrogation could continue if invocation was ambiguous. | Error admitted; harmless as to murder; burglary and abuse of corpse convictions reversed. |
| DNA evidence obtained under mistake exception and constitutional impact | DNA collection violated statute and Fourth/Indiana rights. | Mistake exception validates admissibility; no violation. | DNA evidence admitted under mistake exception; Fourth/Indiana rights not violated. |
| Sentence appropriateness and aggravating/mitigating factors | Trial court erred by misapplying factors. | No abuse of discretion; sentence supported. | Murder sentence affirmed (65 years); burglary/abuse convictions reversed; remand for possible retrial. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (established right to counsel and right to remain silent before custodial interrogation)
- Edwards v. Arizona, 451 U.S. 477 (1981) (interrupts interrogation until counsel is present when requests are unequivocal)
- Davis v. United States, 512 U.S. 452 (1994) (ambiguity in requesting counsel; clarifying questions not required)
- Carr v. State, 934 N.E.2d 1096 (Ind. 2010) (reversal for admission of improperly obtained evidence where others supported guilt)
- Powell v. State, 898 N.E.2d 328 (Ind. Ct. App. 2008) (ambiguous request for counsel not unequivocal; need for clarification)
- Balding v. State, 812 N.E.2d 169 (Ind. Ct. App. 2004) (DNA database collection of convicted offenders upheld under special needs doctrine)
- Evans v. United States, 514 U.S. 1 (1995) (clerical errors of court employees not triggering exclusionary rule)
- Shotts v. State, 925 N.E.2d 719 (Ind. 2010) (Indiana Constitution exclusionary analysis; deterrence and reasonableness)
- Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standard for reviewing sentencing decisions; abuse of discretion)
- Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (factors weighing in sentencing analysis)