Charles Moore v. State of Indiana
2015 Ind. LEXIS 234
| Ind. | 2015Background
- Charles Moore was charged with the murders of Alejandro Tinoco and Jazmin Conlee; he was convicted on multiple counts including felony murder and murder; the jury recommended life without parole for Conlee and the court imposed life without parole for Conlee and 65-year term for Tinoco; Moore appeals solely on sufficiency of the evidence and whether the incredible dubiosity rule should apply; Indiana Supreme Court reviews sufficiency de novo and limits the incredible dubiosity rule to exceptional circumstances; the State presented multiple witnesses and circumstantial evidence linking Moore to the shootings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the incredible dubiosity rule applies. | Moore argues the three main witnesses are inherently inconsistent. | State argues rule applies only in restrictively narrow circumstances. | Inapplicable; evidence from multiple witnesses and circumstantial links supports guilt. |
| Whether the evidence is sufficient to convict Moore for both murders. | Sufficiency is undermined by witness contradictions. | Evidence including DNA and shoeprints, plus multiple witnesses, supports verdict. | Evidence sufficient beyond a reasonable doubt; convictions affirmed. |
| Whether the rule should be expanded to cases with multiple witnesses. | Rule should be extended to protect against inherently dubious multi-witness testimony. | Rule remains limited; not warranted here given corroboration and circumstantial evidence. | Rule not expanded; remains inapplicable under the facts. |
Key Cases Cited
- Gaddis v. State, 253 Ind. 73 (1969) (limited, highly improbable testimony can negate guilt when sole identifying witness is unreliable)
- Tillman v. State, 642 N.E.2d 223 (Ind. 1994) (limits the rule to inherently improbable or coerced testimony with no circumstantial support)
- Murray v. State, 761 N.E.2d 406 (Ind. 2002) (multi-witness case; credibility for the jury; rule not automatically triggered)
- Edwards v. State, 753 N.E.2d 618 (Ind. 2001) (incredible dubiosity requires great ambiguity; not met here)
- Majors v. State, 748 N.E.2d 365 (Ind. 2001) (reliance on incredible dubiosity misplaced where circumstantial evidence exists)