Christopher A. Bruck v. State of Indiana (mem. dec.), 10A05-1612-CR-2865

Background

Four-year-old Hayden Dukes, who had DiGeorge Syndrome, was admitted to hospital after seizures on Jan 3–4, 2015 and later died from a severe subdural hematoma and brain swelling.
Doctors concluded Hayden’s injuries were traumatic (comparable to high-speed crash or multi-story fall) and unlikely to result from running into a door frame or a short fall; one opined a forceful palm strike could cause such injury.
Christopher Bruck (father) initially told doctors Hayden hit a door frame; at Kosair he gave three statements to police: an initial non-culpatory interview, a second un-Mirandized interview admitting he struck Hayden, and a third Mirandized statement repeating the admission. He was arrested after the third interview.
State charged Bruck with Level 1 aggravated battery causing death and Level 1 neglect of a dependent causing death (later reduced one count to Level 6). Bruck moved to suppress the three statements; motion denied. He later moved for $5,000 public funds to hire a defense expert; denied as untimely.
At trial the State presented multiple medical experts (including Dr. Melissa Currie). Jury convicted on both counts; trial court imposed 40 years (aggravated battery) + 2.5 years consecutive (neglect) = 42.5 years. Bruck appealed.

Issues

Issue	State's Argument	Bruck's Argument	Held
1. Were Bruck’s three police statements admissible under Miranda?	Statements admissible because Bruck was not in custody during the critical second (inculpatory) interview; Miranda not required; third statement duplicated second.	Second interview was custodial and thus required Miranda; third was tainted by "question first, warn later" tactic.	Not custodial; second interview lawful; third need not be addressed. Statements admissible.
2. Was corpus delicti established to admit the confessions?	Yes — independent medical evidence showed traumatic injury inconsistent with accident or natural causes, permitting inference a crime caused Hayden’s death.	Insufficient independent evidence linking a crime to the death apart from Bruck’s statements.	Corpus delicti satisfied (evidence death resulted from trauma by someone), so confessions admissible.
3. Could Dr. Currie testify and rely on Bruck’s statements?	Yes — expert may rely on case facts and statements reasonably relied upon in the field; corpus delicti supports that reliance; her testimony was largely cumulative.	Her opinions improperly relied on Bruck’s extra-judicial statements and lacked foundation.	Admissible; even if erroneous, testimony was cumulative and harmless.
4. Was denial of $5,000 public funds for defense expert an abuse of discretion?	Denial proper: request was untimely (made at end of day one of trial), appeared exploratory, and counsel could cross-examine State experts.	Needed an expert to evaluate and rebut State experts’ deposition opinions.	Denial was within trial court’s discretion due to untimeliness and exploratory purpose.
5. Is the 42.5-year aggregate sentence improper or an abuse of discretion?	Aggravators (victim’s young age, disability, presence of other children) supported sentence; mitigators properly considered.	Court ignored certain mitigators (IRAS score, hardship to dependents, mental disability) and over-weighted aggravators.	No abuse of discretion; sentencing claim under Rule 7(B) waived; aggravators and mitigators reasonably applied.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings)
California v. Beheler, 463 U.S. 1121 (1983) (custody inquiry: whether reasonable person would feel free to leave)
Missouri v. Siebert, 542 U.S. 600 (2004) (disapproving "question first, warn later" tactic)
Florida v. Bostick, 501 U.S. 429 (1991) (show of authority required for seizure/custody)
Clark v. State, 994 N.E.2d 252 (Ind. 2013) (standard of review for admission after suppression motion)
Shinnock v. State, 76 N.E.3d 841 (Ind. 2017) (corpus delicti rule: independent evidence that crime was committed by someone)
Walker v. State, 233 N.E.2d 483 (Ind. 1968) (corpus delicti requires proof crime occurred, not necessarily who committed it)
Kocielko v. State, 938 N.E.2d 243 (Ind. Ct. App. 2010) (factors for granting public funds for defense experts)
Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standard for sentencing review and abuse-of-discretion analysis)