Charles Stephenson v. State of Indiana
29 N.E.3d 111
| Ind. | 2015Background
- Charles Stephenson was convicted by a jury of murdering and robbing 67‑year‑old Leigh Jennings in Aurora, IN (victim died of blunt force head trauma; blood on a skillet and pepper mill found in pantry).
- Evidence showed Stephenson's DNA on the pepper grinder and possibly on the skillet; his fingerprint was on a promissory note in a safe; cash was missing from safes; he was seen at Jennings's home and had recent contact with her.
- Stephenson was heavily in debt; he had promissory notes to Jennings for prior loans and was under creditor pressure immediately before the killing.
- Two days after police questioned him, Stephenson made an apparent suicide attempt and left a note denying involvement; police and the jury heard testimony and saw the note at trial.
- Stephenson was convicted of murder and Class A felony robbery and sentenced to life imprisonment without parole under Ind. Code § 35‑50‑2‑9(b)(1)(G) (murder committed while committing or attempting robbery).
Issues
| Issue | State's Argument | Stephenson's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for robbery | Evidence of visit, motive (debt), presence at scene, DNA/fingerprint, missing cash supports robbery | Injury could be a murder alone; taking property may have occurred after killing, so robbery not proved | Jury could reasonably find robbery beyond a reasonable doubt; conviction affirmed |
| Sufficiency of evidence for statutory aggravator (life w/o parole) | Murder occurred while committing or attempting robbery given motive, killing, and taking of cash | Even if robbery occurred, murder was a crime of passion and sequential (not contemporaneous), so aggravator not proved | Evidence sufficient for jury to find murder committed while committing robbery; aggravator proved |
| Admission of suicide‑attempt evidence | Relevant to motive (financial stress) and consciousness of guilt; admissible; defense had opportunity to object | Irrelevant or unduly prejudicial under Evid. R. 401/403; prior‑bad‑act concerns under Evid. R. 404(b) | Trial court did not err: evidence relevant to motive; 404(b) not implicated; no reversible error in admission |
| Admission of testimony about defendant's appearance (euphoric) | Testimony was permissible lay observation | Testimony speculative and suggested guilt/intent | Defendant failed to raise those specific trial objections; no fundamental error; claim waived on appeal |
Key Cases Cited
- Baker v. State, 968 N.E.2d 227 (Ind. 2012) (standard for reviewing sufficiency of evidence)
- Grace v. State, 731 N.E.2d 442 (Ind. 2000) (sufficiency review principles)
- Buggs v. State, 844 N.E.2d 195 (Ind. Ct. App. 2006) (discussing timing of force in robbery context)
- Robinson v. State, 693 N.E.2d 548 (Ind. 1998) (taking property after death can still support robbery if force occurred while victim alive)
- Washington v. State, 808 N.E.2d 617 (Ind. 2004) (applying sufficiency standard to statutory aggravators)
- Cardine v. State, 475 N.E.2d 696 (Ind. 1985) (exclusion of suicide evidence where remote or not probative)
- Kien v. State, 782 N.E.2d 398 (Ind. Ct. App. 2003) (suicide notes excluded where used to impeach on collateral issue)