Brian J. Christlieb v. State of Indiana (mem. dec.)
48A04-1604-CR-930
| Ind. Ct. App. | Dec 5, 2016Background
- In June 2015, Brian J. Christlieb pleaded guilty to two counts of failure to register as a sex/violent offender and received a six-year aggregate sentence: two years executed on home detention and four years suspended to probation.
- An amended notice filed March 3, 2016 alleged Christlieb committed new offenses: false informing and domestic battery (both class A misdemeanors), prompting a revocation hearing.
- On February 7, 2016 officers responded to an apartment in disarray; Christlieb claimed a masked home-invasion had occurred, but the door had been unscrewed from the inside and Christlieb smelled of alcohol.
- Witnesses: three officers testified about the scene, Christlieb’s intoxication, and his jail statements admitting he "beat the s--- out of" his wife and threatened to kill an officer; Officer Stephens relayed statements he said J.C. (Christlieb’s wife) made to him.
- The trial court revoked Christlieb’s suspended sentence and ordered his sentence to be served in the Department of Correction; Christlieb appealed the revocation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Officer Stephens’s testimony recounting J.C.’s statements was admissible in the revocation hearing | State: the hearsay bore substantial guarantees of trustworthiness and supported revocation | Christlieb: the testimony was hearsay and violated his confrontation/due process rights | Court: testimony was substantially trustworthy; admission not an abuse of discretion — admissible |
| Whether admission of that hearsay violated Christlieb’s due process right to confront witnesses | State: probation hearings have narrower confrontation rights; Reyes permits reliable hearsay | Christlieb: required live testimony to confront accuser | Court: Reyes standard applied; confrontation right satisfied because hearsay was trustworthy |
| Whether the evidence presented was sufficient to support revocation by a preponderance | State: officers’ observations, J.C.’s statements (via officer), Christlieb’s jail admissions supported finding he battered J.C. | Christlieb: contention effectively asks appellate court to reweigh credibility | Court: evidence was sufficient; a single proven violation suffices to revoke |
| Whether trial court needed on-record explanation for admitting hearsay | State: Reyes prefers on-record explanation but record may independently show trustworthiness | Christlieb: lack of explicit on-record reliability findings was error | Court: absence of detailed on-the-record explanation not fatal where record supports trustworthiness |
Key Cases Cited
- Reyes v. State, 868 N.E.2d 438 (Ind. 2007) (hearsay admissible in probation revocation if it bears substantial guarantees of trustworthiness)
- Figures v. State, 920 N.E.2d 267 (Ind. Ct. App. 2010) (confrontation rights in revocation hearings are narrower than in criminal trials)
- Cox v. State, 706 N.E.2d 547 (Ind. 1999) (placement in probation/community corrections is a conditional liberty, not a right)
- Monroe v. State, 899 N.E.2d 688 (Ind. Ct. App. 2009) (revocation of community corrections/home detention reviewed like probation revocation; State must prove violations by preponderance)