Douglas A. Guilmette v. State of Indiana
986 N.E.2d 335
Ind. Ct. App.2013Background
- Guilmette was convicted of murder in St. Joseph Superior Court; the State charged him with murder, two thefts, and habitual offender status.
- The State presented evidence that Guilmette had animosity toward Piechocki and that Piechocki’s death involved a baseball bat.
- Guilmette was captured on surveillance driving Piechocki’s car to Walmart and Meijer, where he concealed items and purchased doughnuts.
- A blood/staining incident on Guilmette’s shoe was found during a search incident to a theft arrest and later tested for DNA.
- Witnesses testified that Guilmette admitted killing Piechocki to jailhouse informants and friends, with multiple inmates providing confessions.
- The trial court instructed on accomplice liability; Guilmette was ultimately found guilty and adjudicated an habitual offender.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of DNA evidence from shoe | Guilmette argues the shoe search violated Article 1, Section 11 | Guilmette contends the DNA evidence was improperly admitted | Harmless error; evidence otherwise supported guilt |
| Accomplice liability jury instruction | Court erred in giving accomplice instruction | Sufficient evidence supported instruction | Not an abuse of discretion; instruction supported by evidence |
| Sufficiency of the evidence | Confessions by co-inmates/recanted testimony undermined guilt | Evidence showed guilt beyond reasonable doubt | Sufficient evidence to sustain murder conviction |
Key Cases Cited
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (Indiana reasonable-search test under Article 1, Section 11; totality of circumstances)
- Turner v. State, 953 N.E.2d 1039 (Ind. 2011) (harmless-error standard for improperly admitted evidence)
- Treadway v. State, 924 N.E.2d 621 (Ind. 2010) (sufficiency of evidence review; weight of witness credibility for jury)
- Smith v. State, 765 N.E.2d 578 (Ind. 2002) (no abuse of discretion in accomplice-liability instruction with marginal support)
- Bell v. State, 533 N.E.2d 1238 (Ind. 1989) (inmate-confession evidence adequate to sustain conviction)