Chase Turner v. State of Indiana, 216 N.E.3d 1179

Chase Turner (18) drove a car whose two passengers (including codefendant C.J. Spearman) fired shots at a Kia that had just crashed on I-65; Turner denied firing or intending the shooting and claimed surprise.
Turner was charged and tried as an accomplice to Level 5 felony criminal recklessness; the State’s theory required showing Turner knew of or participated in a plan to shoot.
Turner gave a recorded interview, surrendered his phone passcode, and denied intent; police did not access his phone/certain social media data during the investigation.
At trial ISP Sergeant Hanson testified on redirect that Spearman had “gave [a] complete confession of everything,” prompting an immediate objection and a motion for mistrial by Turner.
The trial court found the remark was an evidentiary harpoon but denied a mistrial, concluding the error could be cured and that there was other evidence supporting the verdict; the jury convicted Turner of criminal recklessness.
The Court of Appeals held the improper testimony placed Turner in grave peril, that the clarification did not cure the prejudice (especially given the halted digital investigation), and reversed and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sergeant Hanson’s statement that Spearman made a “complete confession of everything” was an evidentiary harpoon and impermissible prejudicial testimony	The State (below) conceded the testimony was improper but argued it merely supported that Spearman was the shooter and did not by itself implicate Turner	Turner argued the statement functioned as an inadmissible shortcut implying a broader confession (including any plan implicating Turner), violating confrontation and placing him in grave peril	Court of Appeals: statement was an evidentiary harpoon that created grave peril and was prejudicial; reversal ordered
Whether the trial court’s denial of Turner’s mistrial motion was an abuse of discretion (i.e., whether the error could be cured)	The State argued the error was curable by clarification/admonition and other properly admitted evidence supported the verdict	Turner argued no satisfactory cure existed because the confession suggested coordination/plan and investigators stopped digital forensics after the confession	Court of Appeals: denial was an abuse of discretion because the record could not assure the improper testimony did not influence the jury; new trial ordered

Knapp v. State, 9 N.E.3d 1274 (Ind. 2014) (standard of review for mistrial rulings; trial court discretion)
Agilera v. State, 862 N.E.2d 298 (Ind. Ct. App. 2007) (defendant must show statement placed them in "grave peril")
Perez v. State, 728 N.E.2d 234 (Ind. Ct. App. 2000) (definition and risk of an "evidentiary harpoon")
Smith v. State, 471 N.E.2d 733 (Ind. Ct. App. 1984) (require high assurance that improper testimony did not affect verdict)
White v. State, 272 N.E.2d 312 (Ind. 1971) (error that places defendant in grave peril warrants reversal when its effect on jury cannot be ruled out)
Hightower v. State, 296 N.E.2d 654 (Ind. 1973) (quoted authority on risk from improperly injected evidence)