Christopher Rondeau v. State of Indiana
48 N.E.3d 907
| Ind. Ct. App. | 2016Background
- Defendant Christopher Rondeau was convicted of murder (Adolf Stegbauer) after an April 2009 sword fight in which his grandmother Franziska died and his great-uncle Adolf later died; Rondeau claimed self‑defense.
- Rondeau was sentenced to 55 years; this Court affirmed his conviction on direct appeal.
- Rondeau filed a pro se petition for post‑conviction relief (PCR) alleging, inter alia, judicial bias, procedural errors during PCR, ineffective trial counsel, and ineffective appellate counsel.
- During PCR he sought numerous subpoenas; the court granted some and denied others (some denials lacked on‑the‑record findings as to subpoenas).
- The PCR court allowed the State to substitute signed responses to requests for admission and accepted the State’s belated proposed findings and conclusions; Rondeau objected.
- The PCR court denied relief on all claims; Rondeau appealed and this opinion affirms that denial.
Issues
| Issue | Plaintiff's Argument (Rondeau) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Judicial bias of PCR court | PCR court showed bias via adverse procedural rulings and interventions | Adverse rulings do not prove personal bias; record shows no disqualifying conduct | No bias; adverse rulings alone insufficient to show partiality |
| Permitting substitution/late filings & missed PCR procedures | State’s unsigned responses and late proposed findings prejudiced Rondeau and court erred in accepting them | Substituted/supplemental filings were substantively identical and caused no prejudice | No reversible error; no substantial prejudice shown |
| Denial of subpoena requests during PCR | Court abused discretion in denying subpoenas and sometimes failed to make required findings | Many subpoenas were speculative, irrelevant to PCR ineffective‑assistance claims, or concerned matters available at trial/direct appeal | Denials were within discretion; lack of on‑record finding for one set not reversible where issues were addressed and petitioner showed no prejudice |
| Ineffective assistance of trial and appellate counsel | Trial counsel unprepared, failed to investigate, failed to proffer lesser instructions, failed to move for speedy trial; appellate counsel failed to raise trial‑counsel ineffectiveness | Counsel made strategic decisions, sought continuances/mistrials, cross‑examined witnesses, PCR record lacked proof of prejudice; omitted appellate issues were not obviously stronger | PCR court correctly found no ineffective assistance of trial or appellate counsel under Strickland standard |
Key Cases Cited
- Harrison v. State, 707 N.E.2d 767 (Ind. 1999) (adverse judicial rulings do not alone establish bias)
- Liteky v. United States, 510 U.S. 540 (U.S. 1994) (expressions of impatience or dissatisfaction do not necessarily establish judicial bias)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part test for ineffective assistance: performance and prejudice)
- Timberlake v. State, 753 N.E.2d 591 (Ind. 2001) (deference to counsel’s strategic choices)
- Ben‑Yisrayl v. State, 753 N.E.2d 649 (Ind. 2001) (scope and standard of post‑conviction review)
- Pannell v. State, 36 N.E.3d 477 (Ind. Ct. App. 2015) (denial of subpoena without detailed findings not always reversible where issues are addressed)