Antrooine A. Manning, Jr. v. State of Indiana
2013 Ind. App. LEXIS 457
| Ind. Ct. App. | 2013Background
- Manning appeals the Lake Superior Court’s denial of post-conviction relief after a direct-appeal conviction for robbery and resisting law enforcement, with accomplice liability for the resisting charge alleged.
- Key facts: Manning and Woods fled after Blondeel's purse theft; Manning instructed Woods to 'take off' as police pursued.
- Videos and testimony showed Woods moved the car while police fired at the tires; Manning admitted telling Woods to flee.
- Trial: Manning was convicted of Class B felony robbery, Class D felony resisting law enforcement (as an accomplice), and a habitual offender enhancement; sentence: 30 years total.
- Post-conviction petition asserted ineffective assistance of trial and appellate counsel based on the theory that Woods’s short movement did not constitute fleeing, and that evidence was insufficient, but the petition was denied as barred by res judicata.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does res judicata bar Manning's post-conviction claims? | Manning: claims reargue sufficiency, disguised as ineffective assistance. | State: res judicata precludes rearguments already decided on direct appeal. | Yes; claims barred by res judicata. |
| Was trial/ appellate counsel ineffective for not challenging whether Woods fled by a short distance? | Manning: lack of flight negates accomplice liability. | Woods’ flight evidence supported resisting as an accomplice; challenge would fail. | No deficiency; evidence supported accomplice resisting and no prejudice shown. |
| Was the evidence sufficient to sustain Manning as an accomplice in resisting law enforcement? | Manning contends no flight by Woods means no resister for accomplice liability. | Evidence showed Manning knowingly aided; his directive to Woods to take off supports liability. | Sufficient evidence to convict Manning as an accomplice; affirm denial. |
Key Cases Cited
- Henley v. State, 881 N.E.2d 639 (Ind. 2008) (standard for post-conviction relief and review of findings)
- Ben-Yisrayl v. State, 738 N.E.2d 253 (Ind. 2000) (claim preclusion and res judicata in post-conviction)
- Arthur v. State, 663 N.E.2d 529 (Ind. 1996) (extraordinary circumstances to retreat from prior ruling)
- Wellman v. State, 703 N.E.2d 1061 (Ind. Ct. App. 1998) (definition of flight in resisting law enforcement)
- Jones v. State, 938 N.E.2d 1248 (Ind. Ct. App. 2010) (evidence of flight sufficient where defendant directed to stop)
- Woodward v. State, 770 N.E.2d 897 (Ind. Ct. App. 2002) (evidence of flight sufficient under accomplice theory)