Ceaser v. State
2012 Ind. App. LEXIS 126
| Ind. Ct. App. | 2012Background
- Ceaser was previously convicted in 2006 of battering her seven-year-old daughter M.R., leading to CHINS involvement.
- In 2008, Ceaser beat nine-year-old M.R. with a video-game-controller cord for alleged misconduct with chores and homework; injuries were observed and reported.
- The State charged Ceaser in January 2009 with Class D felony battery on a child.
- At pretrial, the court allowed limited 404(b) evidence relating to the 2006 conviction for rebuttal if parental privilege was claimed, restricting other details of the prior conviction.
- During trial, Ceaser asserted parental privilege; the State presented evidence including the 2006 incident and related statements.
- The jury convicted Ceaser of Class D felony battery on a child; she appealed challenging admissibility, dismissal, and sufficiency of evidence to rebut parental privilege.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior-misconduct evidence | Ceaser: 404(b) evidence irrelevant and prejudicial. | State: prior acts relevant to intent/absence of mistake; admissible with limits. | Admissible under intent and lack of accident/mistake; probative value not outweighed by prejudice. |
| Motion to dismiss under 35-34-1-4(a)(11) | Ceaser: dismissal appropriate; facts insufficient for crime; defense of parental privilege. | State: dismissal inappropriate; issues for trial; parental privilege unresolved. | Court did not err; denial affirmed; parental privilege remains for jury decision. |
| Sufficiency to rebut parental privilege | Ceaser: evidence insufficient to disprove parental privilege. | State: evidence showed unreasonable force or unreasonable belief of necessity. | Evidence sufficient to rebut parental privilege; conviction affirmed. |
Key Cases Cited
- Willis v. State, 888 N.E.2d 182 (Ind. 2008) (establishes parental privilege standards and factors for reasonable force)
- Taylor, 701 A.2d 390 (Md. 1997) (prior acts admissible to show intent/absence of mistake in parental discipline context)
- Kimberly B., 699 N.W.2d 641 (Wis. 2005) (prior beatings admissible to show intent and lack of accident in parental discipline)
- Hicks v. State, 690 N.E.2d 215 (Ind. 1997) (traceable to Rule 404(b) discussion on prior acts)
- Embry v. State, 923 N.E.2d 1 (Ind. Ct. App. 2010) (framework for balancing probative value and prejudice under Rule 403)
- Reeves v. State, 953 N.E.2d 665 (Ind. Ct. App. 2011) (support for admissibility of prior misconduct where intent is at issue)
- Moore v. State, 653 N.E.2d 1010 (Ind. Ct. App. 1995) (discusses reliance on prior acts to show intent when defense places issue at trial)
- State v. Isaacs, 794 N.E.2d 1120 (Ind. Ct. App. 2003) (discusses scope of dismissal and pretrial matters)
- United States v. Harris, 661 F.2d 138 (10th Cir. 1981) (recognizes admissibility of prior acts to show absence of mistake in child abuse cases)