Christopher Compton v. State of Indiana
2016 Ind. App. LEXIS 313
| Ind. Ct. App. | 2016Background
- In March 2014 a fire in a second‑floor Evansville apartment killed three occupants (smoke inhalation/carbon monoxide). Compton had been at the apartment earlier, threatened to "burn this mother f*er to the ground," and was seen walking away as the fire began.
- A neighbor (Iverson) reported Compton admitted he started the fire; police bodycam and a detective interview captured Compton admitting he flicked a cigar/Black & Mild onto a baby stroller, and he was arrested.
- The State charged Compton with three counts of felony murder, multiple arson counts (later dismissed), and alleged habitual offender status. Compton moved to exclude his inculpatory statements, arguing the State failed to prove the corpus delicti of arson independent of his confessions.
- Fire investigator Hunt testified the fire originated at the bottom of the stairwell, found no accelerant, ruled out accidental/natural causes but concluded the origin was "undetermined," i.e., could not exclude intentional ignition.
- During trial the court permitted media to provide live Twitter updates from the courtroom over Compton’s objection; the court also instructed jurors not to consume outside information and took steps to minimize disruption. Jury convicted Compton (guilty but mentally ill) on three counts of felony murder and found him an habitual offender.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether allowing media to Tweet live trial updates deprived defendant of due process | State: Twitter updates do not constitute inherently prejudicial broadcasting; no prejudice shown | Compton: Live tweeting is broadcasting that inherently prejudices jury and violates Rule 2.17 / due process | Court: Broadcasting is not inherently prejudicial here; no specific prejudice shown; admission of tweets did not violate due process (affirmed) |
| Whether the State failed to establish corpus delicti for arson, making confessions inadmissible | State: Independent circumstantial evidence (threats, timeline, location, fire origin ruling out accidental causes) supports inference of arson, so statements admissible | Compton: No proof apart from his statements that an arson occurred; confession alone insufficient | Court: Independent evidence (threats, presence, timing, investigator ruling out accidental causes) sufficed to infer arson; confessions admissible (affirmed) |
Key Cases Cited
- Estes v. Texas, 381 U.S. 532 (1965) (discusses when broadcasting a trial may be inherently prejudicial and require reversal)
- Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555 (1980) (public‑trial and press access principles)
- Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978) (press access and reporting on court proceedings)
- Willard v. State, 272 Ind. 589, 400 N.E.2d 151 (1980) (televising/recording courtroom proceedings must be evaluated case‑by‑case; broadcasting alone does not mandate reversal)
- Sweeney v. State, 704 N.E.2d 86 (Ind. 1998) (corpus delicti rule requires independent evidence that the specific crime occurred and someone’s criminal act caused it)
- Fox v. State, 179 Ind. App. 267, 384 N.E.2d 1159 (1979) (arson proof is often circumstantial; negative evidence ruling out accidental causes can support arson inference)