Daniel Ray Wilkes v. State of Indiana
984 N.E.2d 1236
| Ind. | 2013Background
- Daniel Wilkes was convicted of the 2006 murders of Donna Claspell and her two daughters and sentenced to death after a penalty-phase verdict upholding aggravators.
- The post-conviction court reduced Wilkes’s sentence to life without parole and denied most of his post-conviction relief claims.
- Wilkes contends trial counsel were ineffective for (a) failing to investigate/present exculpatory evidence, (b) failing to question Juror A during voir dire, (c) failing to preserve objections to voir dire time limits, (d) juror misconduct by Juror A, and (e) discovery/in camera review of Juror A’s family records.
- The State argues trial strategy and the record support the post-conviction court’s findings and that Wilkes failed to prove prejudice under Strickland.
- This appeal challenges the post-conviction court’s denial of Wilkes’s requests for new trial relief and restoration of the death sentence, now seeking reversal or remand for trial relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for failing to investigate/present exculpatory evidence | Wilkes argues trial counsel did not fully investigate/present neighbors’ testimony, cell-phone data, and Spradley lead. | State contends trial strategy reasonably aimed to undermine State’s theory and evidence; additional evidence wouldn’t change outcome. | Not shown; strategy reasonable, no prejudice proven. |
| Failure to question Juror A during voir dire | Juror A’s incomplete questionnaire answers could have exposed bias against mitigation. | Trial counsel exercised discretion; reliance on questionnaires was tactical and within bounds. | Not entitled to relief; no proven ineffectiveness. |
| Failure to preserve objection to voir dire time limits | Time limits prevented full voir dire that could have revealed prejudice. | Trial court’s discretionary control over voir dire; no prejudice shown. | No reversible error; no prejudice under Strickland. |
| Juror A misconduct imputed to implicate impartiality | Juror A’s omissions and deposition statements show potential bias against mitigation. | No gross misconduct; juror impartiality not demonstrated. | No gross misconduct; no basis for new trial. |
| Discovery/in camera review of Juror A’s family mental health records | Post-conviction denial barred access to confidential records needed to prove bias. | Privacy interests outweigh need; records obtained and discussed; no abuse of discretion. | Ruling not clearly erroneous; no entitlement to discovery. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
- Ward v. State, 969 N.E.2d 46 (Ind. 2012) (reasonable deference to counsel decisions; standards for prejudice)
- Ben-Yisrayl v. State, 738 N.E.2d 253 (Ind. 2000) (post-conviction standard; rule on available grounds and res judicata)
- Pruitt v. State, 903 N.E.2d 899 (Ind. 2009) (issues must be known or available; ineffective assistance framework)
- Allen v. State, 749 N.E.2d 1158 (Ind. 2001) (limits on grounds; deference to trial strategy)
- Dye v. State, 784 N.E.2d 469 (Ind. 2003) (gross misconduct standard; due process considerations)
- McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (U.S. 1984) (duty of jurors to answer questions truthfully; standard for challenge for cause)
- Kubsch v. State, 934 N.E.2d 1138 (Ind. 2010) (application of Strickland and defense strategy deference)