Engelica E. Castillo v. State of Indiana
2012 Ind. LEXIS 641
| Ind. | 2012Background
- Defendant Engelica Castillo was convicted of Murder, two counts of Neglect of a Dependent, one count of Battery (reduced to a class D felony), and False Informing; Battery later vacated, sentences to run consecutively with life without parole for Murder and additional fixed years for other counts.
- The victim was two-year-old Jada Justice; death occurred June 13, 2009, with autopsy indicating blunt force head injury or asphyxiation as potential causes.
- Castillo’s codefendant, Timothy J. Tkachik, pleaded guilty to Neglect of a Dependent and testified against Castillo; he faced a maximum sentence of 50 years per count under a plea agreement.
- The trial court sentenced Castillo to life without parole for Murder and added terms for Neglect of a Dependent and False Informing; these sentences were ordered to run consecutively.
- Castillo challenged the sentence on direct appeal, arguing (1) life without parole was inappropriate and (2) prosecutorial misconduct during sentencing.
- The appellate court revised Castillo’s Murder sentence to 65 years and found prosecutorial misconduct but did not grant further relief beyond the revised sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is life without parole for murder appropriate given the facts? | State contends LWOP warranted by victim’s age and circumstances. | Castillo argues LWOP is inappropriate given accomplice liability and lack of intent to kill. | 65-year term for Murder; LWOP deemed inappropriate under the circumstances. |
| Did prosecutorial misconduct at sentencing require relief? | State asserts closing statements were within bounds or harmless. | Castillo argues prosecutorial misstatements and character invocations violated law and fairness. | Misconduct found; however, no further relief beyond the revised 65-year sentence. |
Key Cases Cited
- Baxter v. State, 727 N.E.2d 429 (Ind. 2000) (reduced accomplice murder sentence based on defendant’s role and character)
- Edgecomb v. State, 673 N.E.2d 1185 (Ind. 1996) (revising murder sentence for lesser culpability when not primary actor)
- Cooper v. State, 854 N.E.2d 831 (Ind. 2006) (prosecutorial misconduct standard; adverse impact on sentencing)
- Jester v. State, 724 N.E.2d 235 (Ind. 2000) (accomplice liability doctrine; principal vs accomplice)
- Williams v. State, 749 N.E.2d 1139 (Ind. 2001) (awareness of high probability to kill; intent standards)
- Burkhalter v. State, 272 Ind. 282, 397 N.E.2d 598 (Ind. 1979) (definition of intentional/knowingly and high-probability standards)