Andrew S. Satterfield v. State of Indiana, 2015 Ind. LEXIS 568

In December 2011 Andrew Satterfield shot and killed his mother, poured gasoline in their home, locked the doors, and set the house on fire; he later fled and sought medical treatment for burns.
Indictments: murder (while committing arson), arson, and attempted arson; jury convicted on all counts and recommended life without parole (LWOP) under I.C. § 35-50-2-9(b)(1)(A).
Defense: not responsible by reason of insanity or, alternatively, guilty but mentally ill; three experts testified with conflicting diagnoses (two diagnosing schizophrenia, one attributing symptoms to substance abuse and jail psychosis).
Additional evidence included recorded hospital interrogation, witness testimony about Satterfield’s behavior (e.g., remaining in underwear, not immediately seeking help), and evidence of deception (e.g., nondisclosure on handgun form, selective use of diagnoses).
Trial court admitted a detective’s characterization of Satterfield’s answers as "evasive"; jury rejected mental-health defenses, convicted, and jury recommended LWOP; Satterfield appealed directly to the Indiana Supreme Court.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Satterfield)	Held
Whether the jury’s rejection of insanity / guilty-but-mentally-ill defenses was contrary to law	Jury verdict should stand — evidence conflicted and jury resolves credibility	Jury should have found him insane or guilty but mentally ill given expert testimony diagnosing schizophrenia	Affirmed: verdict not contrary to law; evidence conflicted and jurors may disbelieve experts
Admissibility of detective’s testimony characterizing interview answers as "evasive"	Testimony admissible as lay opinion summarizing observations of defendant’s answers	Testimony was improper skilled-witness or "human lie detector" testimony and prejudicial to insanity defense	Affirmed: not abuse of discretion; admissible as lay opinion and not a prohibited credibility determination
Whether detective’s testimony impermissibly commented on veracity	State: testimony summarized manner of answering, not truthfulness	Satterfield: term "evasive" implies deception and invades jury role on credibility	Held: in context, not a comment on truthfulness; video corroborated characterization
Appropriateness of LWOP under App. R. 7(B)	LWOP appropriate given brutal facts and offender’s character (deception, substance abuse)	LWOP inappropriate—mitigate because of mental illness	Affirmed: LWOP not inappropriate in light of nature of the offense and Satterfield’s character

Galloway v. State, 938 N.E.2d 699 (Ind. 2010) (jury determines sanity and weighs conflicting mental-health evidence)
Myers v. State, 27 N.E.3d 1069 (Ind. 2015) (standards for insanity and deference to jury credibility determinations)
Hurst v. State, 699 N.E.2d 651 (Ind. 1998) (guilty but mentally ill principles and jury role)
Tolliver v. State, 922 N.E.2d 1272 (Ind. Ct. App. 2010) (lay-observer characterization of behavior admissible under Evidence Rule 701)
Kubsch v. State, 784 N.E.2d 905 (Ind. 2003) (distinguishing skilled witnesses from ordinary lay testimony)
McCutchan v. Blanck, 846 N.E.2d 256 (Ind. Ct. App. 2006) (opinion testimony is helpful when it gives substance to facts difficult to articulate)
K.W. v. State, 984 N.E.2d 610 (Ind. 2013) (court may review video evidence admitted at trial)
Blount v. State, 22 N.E.3d 559 (Ind. 2014) (abuse-of-discretion standard for evidentiary rulings)
Clark v. State, 808 N.E.2d 1183 (Ind. 2004) (affirming trial court on any theory supported by the evidence)
Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (Appellate Rule 7(B) standard; appellate discretion to revise sentences)
Knapp v. State, 9 N.E.3d 1274 (Ind. 2014) (constitutional authority for appellate sentence review)
Conley v. State, 972 N.E.2d 864 (Ind. 2012) (burden on defendant to show sentence inappropriate under Rule 7(B))