Crawford v. State, 946 N.E.2d 1221

Appellant-Defendant Lamar M. Crawford was convicted of murder in Indiana after a jury trial and sentenced to an aggregate 85-year term.
The crime involved the April 9, 2009 killing of Gernell Jackson with forty stab and cut wounds; Crawford was linked to Jackson by DNA and by use of Jackson's property.
Crawford allegedly visited his uncle (Jackson) and used Jackson's car; he later attempted to withdraw funds with Jackson's debit card and pawned Jackson's JVC receiver.
A non-party television production company, Lucky Shift, filmed the investigation and Crawford sought production of all related footage under Trial Rule 26 from Lucky Shift.
The trial court granted some requests and quashed others for lack of particularity; Crawford appealed the quashings.
On appeal, the court affirmed the murder conviction and held the discovery rulings were not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion denying part of discovery	Crawford argues requests were sufficiently particular and material	State argues requests were fishing expeditions and overly broad	No abuse; requests lacked sufficient particularity
Whether the State proved murder beyond a reasonable doubt	Circumstantial evidence does not refute defense claim	Evidence could support defense theory of intruder; DNA and other items are ambiguous	Sufficient evidence supported conviction

WTHR-TV v. Milam, 690 N.E.2d 1174 (Ind. 1998) (defendant entitled to discovery from non-parties when particular and material)
Cline, 693 N.E.2d 4 (Ind. 1997) (particularity of footage; fishing expedition precautions)
Milam, 690 N.E.2d 1175 (Ind. 1998) (require precise, narrow requests for discovery)
Dillard v. State, 274 N.E.2d 392 (Ind. 1971) (rejected overly broad discovery requests as rummaging police files)
Williams v. State, 819 N.E.2d 384 (Ind. Ct. App. 2004) (sufficient particularity when identifying a specific source and timeframe)