David J. Morris v. State of Indiana (mem. dec.), 46A04-1701-CR-167

Victim Hufracio Arteaga was found stabbed to death at a car dealership on April 23, 2016; vehicles, keys, wallet, and credit cards were missing.
Surveillance video from April 21 showed a man matching Morris’s clothing take a green Subaru from the lot; dealership owner reported the Subaru stolen.
Officers surveilled Morris on April 25 at the courthouse, observed him wearing the same clothes, followed and arrested him for auto theft; he was handcuffed and taken to the station.
At the station, after Miranda warnings and a signed waiver, Morris admitted breaking into the dealership, stealing the Subaru and later other items, and using Arteaga’s credit card; physical evidence (blood/DNA, keys, pawn receipt, surveillance tying him to a stolen Hyundai) corroborated involvement in the crime.
Morris was charged with murder, felony murder (merged), two counts of Level 4 burglary, two counts Level 6 auto theft, and Level 6 fraud; he was convicted by a jury and sentenced to an aggregate 82 years.
Pretrial, Morris sought suppression of statements and fruit of the arrest as obtained after an unlawful arrest; trial court found probable cause for the April 25 arrest and denied suppression; Morris also moved for mistrial after a brief reference to "Mindsight Consultants."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of post-arrest statements (Fourth Amendment)	State: officers had probable cause to arrest for auto theft based on surveillance video and identification, so statements were admissible	Morris: arrest lacked probable cause; statements and evidence should be suppressed as fruit of unlawful arrest	Court: Probable cause existed to arrest for auto theft; statements admissible
Denial of mistrial for reference to "Mindsight Consultants"	State: reference was innocuous, no explicit "polygraph" mentioned, and any effect was minor given strong evidence	Morris: "Mindsight" is synonymous with polygraphs locally; mention violated motion in limine and prejudiced jury	Court: No showing Mindsight is understood as polygraph; passing reference not prejudicial in light of overwhelming evidence; mistrial denial proper

Washington v. State, 784 N.E.2d 584 (Ind. Ct. App. 2003) (standard for reviewing admissibility challenges made at trial)
Widduck v. State, 861 N.E.2d 1267 (Ind. Ct. App. 2007) (framing review when defendant proceeds to trial after suppression denial)
Sears v. State, 668 N.E.2d 662 (Ind. 1996) (probable cause arrest without warrant explained)
Ortiz v. State, 716 N.E.2d 345 (Ind. 1999) (officer may arrest without warrant when probable cause exists)
Isom v. State, 41 N.E.3d 469 (Ind. 2015) (abuse-of-discretion standard for mistrial rulings)
Glenn v. State, 796 N.E.2d 322 (Ind. Ct. App. 2003) (references to polygraphs generally inadmissible without agreement)