Christopher Buckhalter v. State of Indiana (mem. dec.), 49A02-1511-CR-1852

On May 24, 2014 in the Coke Lot near the Indianapolis Motor Speedway, Nicholas Castorena was involved in two altercations with the same group; during the first he was struck in the face and clearly saw the attacker’s face.
After a later, separate violent encounter involving the group, Speedway police arrived; Castorena, while walking with Officer Pridemore, pointed out the group standing together and talking.
Officer Pridemore radioed a detective, the individuals were detained, and in a show-up Castorena identified Christopher Buckhalter as the person who hit him in the face.
Buckhalter was charged with Class A misdemeanor battery; at a bench trial the court admitted the show-up and in-court identifications over Buckhalter’s objections and convicted him.
Buckhalter appealed, arguing the show-up seizure lacked reasonable suspicion (Fourth Amendment), the in-court ID was tainted as fruit of the poisonous tree, and the in-court ID lacked an independent basis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of show-up (Fourth Amendment seizure)	State: detention was supported by witness pointing out suspects after two altercations; officer had particularized basis to detain.	Buckhalter: no individualized reasonable suspicion; being a Black male at the lot was insufficient and record lacks justification for the seizure.	Court: No abuse of discretion; the witness’s identification and circumstances provided specific, articulable facts supporting the investigative detention.
Admissibility of in-court ID (taint/independent basis)	State: even if there was a show-up, Castorena had an independent basis to identify Buckhalter (close proximity, clear view, certainty).	Buckhalter: in-court ID was fruit of the poisonous tree from an unlawful show-up and lacked independent basis.	Court: No illegal seizure occurred, so no fruit-of-the-poisonous-tree; applying Hyppolite factors, Castorena had an independent basis for a reliable in-court identification.

Clark v. State, 994 N.E.2d 252 (Ind. 2013) (standard for reviewing evidentiary rulings and abuse of discretion)
C.H. v. State, 15 N.E.3d 1086 (Ind. Ct. App. 2014) (Terry stop analysis and reasonable suspicion applied to brief detentions)
Moultry v. State, 808 N.E.2d 168 (Ind. Ct. App. 2004) (police may briefly detain on reasonable suspicion for investigative purposes)
Terry v. Ohio, 392 U.S. 266 (U.S. 1968) (foundational decision permitting investigatory stops on reasonable suspicion)
Hyppolite v. State, 774 N.E.2d 584 (Ind. Ct. App. 2002) (factors for determining independent basis for in-court identifications)
Gyamfi v. State, 15 N.E.3d 1131 (Ind. Ct. App. 2014) (defendant must show an illegal seizure to invoke fruit-of-the-poisonous-tree)
Mahl v. Aaron, 809 N.E.2d 953 (Ind. Ct. App. 2004) (waiver of state-constitutional claims raised first on appeal)