Clarence Parsley v. State of Indiana (mem. dec.), 48A02-1511-CR-1989

In May 2011, while both incarcerated at Pendleton Correctional Facility, Clarence Parsley stabbed fellow inmate Timothy Knapp during recreation; Knapp sustained ~40 stab wounds and died.
Parsley was charged with murder and prisoner possessing a dangerous device/material; trial occurred June 2–5, 2015.
The State introduced autopsy photos and, through the victim’s mother, a noncontemporaneous wedding photograph of Knapp (waist-up portrait) to identify the victim and show he was alive before the killing.
Parsley objected to the wedding photo as cumulative and prejudicial victim-impact evidence; the trial court admitted it.
Parsley wore ankle restraints (normally hidden at defense table) that would likely be visible to jurors when he testified; the court refused to remove them but offered alternatives which Parsley rejected and he testified from the stand with restraints.
The jury convicted Parsley on both counts; he was sentenced to consecutive terms (60 years murder; 15 years possession). On appeal he challenged admission of the wedding photo and the visible shackling while testifying.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of pre-death wedding photograph of victim	Photo was relevant to identity and to prove victim was alive pre-mortem	Photo was cumulative, prejudicial, and victim-impact evidence meant to inflame the jury	Admission was error but harmless given overwhelming independent evidence of guilt; conviction affirmed
Jury viewing defendant in ankle restraints while testifying	Restraints were necessary for courtroom safety given violent history and security classification	Visible shackling undermined presumption of innocence and treated defendant differently from other witnesses	Court did not abuse discretion: restraints justified by security risk, alternatives offered, and no showing jurors actually saw shackles or were significantly prejudiced

Wilson v. State, 765 N.E.2d 1265 (Ind. 2002) (photographs admissible if relevant and not unduly prejudicial)
Humphrey v. State, 680 N.E.2d 836 (Ind. 1997) (pictures of a victim taken during life are relevant to show victim was alive before murder; caution against victim-impact use)
Pittman v. State, 885 N.E.2d 1246 (Ind. 2008) (photograph of victim during life is technically relevant though often unnecessary)
Payne v. State, 854 N.E.2d 7 (Ind. Ct. App. 2006) (harmless-error standard for erroneously admitted evidence)
Bivins v. State, 642 N.E.2d 928 (Ind. 1994) (defendant generally entitled to appear before jury unrestrained absent necessity)
Wrinkles v. State, 749 N.E.2d 1179 (Ind. 2001) (presumption of innocence requires guarding against visible restraints that imply guilt)
Forte v. State, 759 N.E.2d 206 (Ind. 2001) (review of shackling for abuse of discretion; court may consider defendant’s history and security risks)