Arnell Lyles v. State of Indiana (mem. dec.)
49A02-1603-CR-667
| Ind. Ct. App. | Oct 12, 2016Background
- On Dec. 18, 2013 IMPD executed a no‑knock warrant at a residence; Arnell Lyles was the sole occupant found in the kitchen.
- Police recovered 19 pre‑tied bindles of crack cocaine on the kitchen counter, about $295 tucked under a microwave, two cell phones in the kitchen, and $195, a wallet, two cell phones, and dice on Lyles’s person.
- A loaded .38 revolver was found inside a small refrigerator; a box of matching .38 ammunition was recovered from a kitchen drawer and bore Lyles’s fingerprint; photos on two phones included pictures of Lyles and a gun resembling the recovered pistol.
- Lyles was charged with Dealing in Cocaine (Class A) and Possession of Cocaine (enhanced because of a firearm); the State later dismissed the firearm enhancement pretrial, and the possession count was merged at sentencing.
- Jury convicted Lyles of Dealing in Cocaine; he was sentenced to an aggregate term with part executed in DOC and part in community corrections; Lyles appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admitting the search warrant and testimony that a judge credited police statements was fundamental error | State: admission was not objected to at trial and, in context, did not produce fundamental error given the evidence | Lyles: warrant and Detective Kumbi’s testimony implied judicial validation of police allegations (e.g., trafficking, pre‑recorded buy, weapons) and prejudiced the jury, destroying presumption of innocence | Court: No fundamental error — even if admission was improper, independent and substantial evidence of guilt made any error harmless |
Key Cases Cited
- Guajardo v. State, 496 N.E.2d 1300 (Ind. 1986) (probable cause affidavits and warrants generally inadmissible at trial because they can prejudice the jury)
- Brown v. State, 746 N.E.2d 63 (Ind. 2001) (erroneous admission of warrant may be harmless where independent evidence strongly supports conviction)
- Halliburton v. State, 1 N.E.3d 670 (Ind. 2013) (defendant’s failure to object waives appellate review except for narrow fundamental‑error doctrine)
- Clark v. State, 379 N.E.2d 987 (Ind. Ct. App. 1978) (warrant affidavits can contain highly prejudicial statements and thus are inappropriate for the jury)