Eugene Croffett v. State of Indiana (mem. dec.)
82A01-1606-CR-1428
| Ind. Ct. App. | May 4, 2017Background
- Eugene Croffett, charged with multiple counts of child molesting and alleged habitual offender; convicted on one Level 4 felony count and admitted habitual offender status. Sentenced to 6 years plus 10-year enhancement.
- Incident alleged: during a 2015 family party, Croffett allegedly entered five-year-old L.C.’s bedroom and touched her genitals and anal area; other family members reported discomfort from prior odd remarks to older daughter M.C.
- L.C. identified Croffett in a photo lineup after initially referring to the perpetrator as "Uncle Nate."
- At police station, Croffett was advised of Miranda rights, signed a waiver, and was interviewed twice by Detective Turpin; Croffett denied the molestation and consented to DNA collection.
- During interrogation, Detective Turpin asked Croffett to write an apology letter; Croffett wrote a short note saying he was sorry for what happened to L.C.; the note was admitted into evidence without objection at trial.
- On appeal Croffett argued fundamental error because the handwritten note was involuntary due to deceptive interrogation tactics; the Court of Appeals affirmed, finding no fundamental error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of handwritten apology note | Note was admissible; evidence for jury to weigh | Note was involuntary due to police deception and should not have been admitted; fundamental error because no objection at trial | Admission did not constitute fundamental error; statement was not involuntary and did not make a fair trial impossible |
Key Cases Cited
- Boatner v. State, 934 N.E.2d 184 (Ind. Ct. App. 2010) (trial court’s evidentiary rulings reviewed for abuse of discretion)
- Brown v. State, 929 N.E.2d 204 (Ind. 2010) (preservation rule for evidentiary objections)
- Sampson v. State, 38 N.E.3d 985 (Ind. 2015) (standard for review under fundamental error doctrine)
- Malloch v. State, 980 N.E.2d 887 (Ind. Ct. App. 2012) (totality-of-the-circumstances test for voluntariness of statements)
- Pierce v. State, 761 N.E.2d 821 (Ind. 2002) (police deception is a factor but not dispositive in voluntariness analysis)
- Parsons v. State, 333 N.E.2d 871 (Ind. Ct. App. 1975) (distinguishing confessions from admissions)
- Knight v. State, 436 N.E.2d 866 (Ind. Ct. App. 1982) (further discussion on admissions versus full confessions)