Bradley Baldwin v. State of Indiana (mem. dec.)
49A05-1609-CR-2025
| Ind. Ct. App. | May 11, 2017Background
- On Jan. 19, 2015, Bradley Baldwin and others used drugs at a "trap house"; later that night Baldwin shot Dustin Houghton (killing him) and Ronald Scheible (wounding him) in an alley behind a house on Belmont Avenue. Baldwin fled and returned to the trap house where two revolvers were hidden in a basement flue.
- Witnesses (Davis, Warner, Scheible, Myers) placed Baldwin at the scene and testified he fired the revolver shots; Myers helped hide the guns and led police to them.
- Baldwin was charged with murder, attempted murder, and unlawful possession of a firearm by a serious violent felon; he was convicted by jury and adjudicated a habitual offender.
- At trial Baldwin sought to admit testimony (Detective Howard) that Timothy Browers fired a semi-automatic at a vehicle on Creston Drive the same night; the trial court excluded this as irrelevant/exculpatory evidence.
- Between trial days a juror (K.W.) texted attorney-friends asking about the burden/definition of proof; those attorneys alerted the court. Baldwin moved for mistrial alleging juror misconduct; the trial court denied the motion.
Issues
| Issue | State's Argument | Baldwin's Argument | Held |
|---|---|---|---|
| Exclusion of evidence that Browers fired at a car on Creston Drive same night | Evidence irrelevant and not exculpatory because (a) no proof Browers was at Belmont, (b) Browers used a semi-automatic while victims were shot with a revolver | Evidence tended to show Browers’s involvement and could support alternate-perpetrator theory; Scheible suggested Browers was involved | Court affirmed exclusion: evidence not relevant or exculpatory; even if erroneous, exclusion was harmless given strong evidence implicating Baldwin |
| Denial of mistrial for juror K.W.’s texts to attorneys about burden of proof | State conceded texts satisfied the two-part Ramirez showing but argued it rebutted the presumption of prejudice because K.W. didn’t share info, relied on court instructions, and verdict was impartial | Baldwin argued prejudice was irrebuttable (egregious misconduct) or, if rebuttable, State failed to show harmlessness | Court held misconduct was inappropriate but not egregious; State sufficiently rebutted presumption—trial court did not abuse discretion; no mistrial required |
Key Cases Cited
- Satterfield v. State, 33 N.E.3d 344 (Ind. 2015) (trial courts have broad evidentiary discretion)
- Jacobs v. State, 22 N.E.3d 1286 (Ind. 2015) (standard for abuse of discretion review)
- Tibbs v. State, 59 N.E.3d 1005 (Ind. Ct. App. 2016) (definition of exculpatory evidence and relevance requirement)
- Montgomery v. State, 21 N.E.3d 846 (Ind. Ct. App. 2014) (harmless-error standard for excluded evidence)
- Ramirez v. State, 7 N.E.3d 933 (Ind. 2014) (two-part test for presumed juror prejudice and framework for mistrial analysis)
- May v. State, 716 N.E.2d 419 (Ind. 1999) (examples of irrebuttable prejudice requiring new trial)
- Kelley v. State, 555 N.E.2d 140 (Ind. 1990) (egregious juror contact with prosecution witness can create irrebuttable prejudice)
- Woods v. State, 119 N.E.2d 558 (Ind. 1954) (prima facie prejudice where witnesses met jurors during recesses)
- Weisheit v. State, 26 N.E.3d 3 (Ind. 2015) (appellate review of mistrial denial is for abuse of discretion)
- Bisard v. State, 26 N.E.3d 1060 (Ind. Ct. App. 2015) (juror internet research not necessarily irrebuttable; trial court best positioned to assess prejudice)