Christopher Helsley v. State of Indiana, 2015 Ind. LEXIS 827

Christopher Helsley, a Pike County EMT, was convicted of murdering two coworkers in April 2001 by multiple close-range gunshots to head/neck; both victims were found seated in recliners at the ambulance "barn."
Original 2002 trial: guilt and sentencing phases; jury recommended life without parole (LWOP); conviction and sentence affirmed on direct appeal (2004).
Helsley obtained post-conviction relief in part via an agreement with the State: a new sentencing hearing was held in 2013 limited to whether LWOP or a term of years should be imposed; convictions remained intact.
At the resentencing jury trial the State proved the statutory aggravator (commission/conviction for another murder); the jury found the aggravator outweighed mitigating circumstances and again recommended LWOP; the trial court imposed LWOP.
Helsley appealed, arguing (1) this Court should revise the LWOP sentence under Indiana Appellate Rule 7(B) in light of his character (including alleged mental illness and lack of prior record), and (2) the jury abused its discretion in weighing aggravating vs. mitigating circumstances.

Issue	State's Argument	Helsley's Argument	Held
Whether this Court should revise LWOP under Ind. App. R. 7(B)	Nature of crime (execution-style double murder) warrants deference to jury/trial court; aggravator of highest order outweighs mitigators	LWOP is inappropriate given his difficult childhood, lack of criminal history, and serious mental illness (borderline personality disorder, anxiety, depression, dissociation)	Denied — nature of offense and defendant's character do not present compelling basis to revise sentence under Rule 7(B)
Whether the jury abused its discretion in weighing aggravating and mitigating factors	Balancing is the jury’s province under statute; weighing is not reviewable as abuse of discretion	Jury gave excessive weight to aggravator; mitigators (childhood, mental illness, remorse, no prior record) should have prevailed	Denied — jury weighing/balancing is nonjusticiable and not subject to appellate review once statutory aggravator is found

King v. State, 894 N.E.2d 265 (Ind. Ct. App. 2008) (defines standard under Rule 7(B) review)
Stephenson v. State, 29 N.E.3d 111 (Ind. 2015) (adhere to deference to trial court unless compelling evidence shows inappropriateness)
Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (sentencing is a discretionary function warranting deference)
Ritchie v. State, 809 N.E.2d 258 (Ind. 2004) (once statutory aggravator found, weighing is placed with the jury and is not measured beyond reasonable doubt)
Bivins v. State, 642 N.E.2d 928 (Ind. 1994) (weighing mitigators and aggravators is a jury balancing process)
McManus v. State, 814 N.E.2d 253 (Ind. 2004) (discusses jury weighing role)
Weisheit v. State, 26 N.E.3d 3 (Ind. 2015) (jury not required to list or explain mitigating circumstances)
Ward v. State, 903 N.E.2d 946 (Ind. 2009) (limits on post hoc judicial review of jury deliberations)