Coy Daniels v. State of Indiana (mem. dec.)
49A04-1701-PC-60
| Ind. Ct. App. | Oct 24, 2017Background
- On November 17, 2007, Daniels and several co-defendants entered a dice game residence and shots were fired; one victim (Arnold Fitzgerald) died from a .40 caliber gunshot. Daniels was linked to the scene by witness identifications and post-shooting statements among the group.
- Daniels was charged with murder, felony murder, robbery (Class A felony), and battery (Class C). After a mistrial, a second jury convicted him and the court imposed an aggregate 55-year sentence.
- Daniels’ direct appeal affirmed the convictions. He later filed a petition for post-conviction relief in 2011, proceeded pro se for parts of the process, then obtained counsel (Jonathan Gotkin) who amended the petition and represented him at evidentiary hearings in 2015–2016.
- The post-conviction court held evidentiary hearings over multiple days, excluded various proffered exhibits for lack of foundation or because they were not part of the trial/appellate record, denied a subpoena request for a detective, and denied Daniels’ motion to withdraw his petition.
- The post-conviction court denied relief on all claims (ineffective assistance of trial and appellate counsel; ineffective assistance of post-conviction counsel), and Daniels appealed; the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument (Daniels) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1. Whether court abused discretion by denying Daniels’ pro se motion to withdraw his PCR petition | Motion was timely under prison mailbox rule and should have been allowed to withdraw without prejudice | Court acted within discretion; Daniels was represented by counsel and permitting withdrawal after extensive proceedings would waste judicial resources | Denial affirmed: court not required to accept pro se filings while counsel represented him; denial not an abuse of discretion |
| 2. Whether court erred by denying subpoena for Detective Benner | Benner’s testimony was necessary to authenticate exhibits and show trial counsel failed to investigate | Daniels failed to show relevance/probativeness; issue inadequately briefed | Denial affirmed: waiver for inadequate briefing; no abuse of discretion because Daniels did not demonstrate relevance |
| 3. Whether court improperly excluded various proffered exhibits | Court’s procedural handling prevented admission of pro se evidence and deprived Daniels of record support | Many exhibits were not in trial/appellate record and lacked authentication/foundation | Exclusion affirmed: waived on appeal for lack of cogent argument; exhibits lacked foundation or were outside judicial notice scope |
| 4. Whether post-conviction court erred in denying PCR claims including ineffective assistance of trial/appellate/post-conviction counsel (multiple subclaims: failure to investigate, jury instructions/verbals, verdict forms, double jeopardy) | Counsel failed to investigate, should have objected to verdict forms/instructions, and post-conviction counsel abandoned him | State: counsel’s strategy was reasonable; objections would have failed or were meritless; post-conviction counsel actively represented Daniels | Denial affirmed: appellate waiver for inadequate briefing; on merits, trial counsel’s performance not shown deficient or prejudicial; verdict forms not improper; merger cured double jeopardy concern; post-conviction counsel did not abandon client |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong ineffective-assistance standard: deficient performance and prejudice)
- Wesley v. State, 788 N.E.2d 1247 (Ind. 2003) (explains prejudice prong and reasonable-probability standard in Indiana ineffective-assistance analysis)
- Timberlake v. State, 753 N.E.2d 591 (Ind. 2001) (courts may dispose of ineffectiveness claims by lack of prejudice when appropriate)
- Kitchell v. Franklin, 26 N.E.3d 1050 (Ind. Ct. App. 2015) (verbatim adoption of proposed findings not inherently suspect)
- McKnight v. State, 1 N.E.3d 193 (Ind. Ct. App. 2013) (discusses counsel’s duty to investigate and deference to tactical decisions)
- Laux v. State, 821 N.E.2d 816 (Ind. 2005) (no double jeopardy violation when murder and felony-murder convictions are merged)
- Beattie v. State, 924 N.E.2d 643 (Ind. 2010) (addresses inconsistent-verdict challenges on direct appeal)
- Batalis v. State, 887 N.E.2d 106 (Ind. Ct. App. 2008) (use of special verdict forms to allocate principal vs. accomplice liability is not required)