Jacob Fuller v.State of Indiana
2014 Ind. LEXIS 448
| Ind. | 2014Background
- Fuller, a 15-year-old waived to adult court for two murders and robbery, was sentenced to 150 years consecutive after trial in the juvenile-to-adult waiver context.
- The State introduced contemporaneous evidence including a handgun recovered at scene, photo/video evidence, and a contemporaneous Brown/Smith testimony implicating Fuller.
- Fuller was convicted of two counts of murder and a Class B robbery (after trial adjustments) but acquitted of burglary and theft.
- Trial court found aggravating factors (criminal history, conspiracy, presence of a minor witness, multiple deaths) and one mitigating factor (youth) and imposed maximum terms.
- Indiana appellate review under Appellate Rule 7(B) allows revisiting a sentence to determine if it is inappropriate in light of the offense and offender.
- This matter follows Brown v. State, where the court revised a youthful offender’s sentence, and the court confirms it has authority to revise Fuller’s sentence as well.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 7(B) revision standard supports reducing Fuller’s sentence | State urged deference to trial court and affirmed sentence’s appropriateness | Fuller argued the sentence is excessive given his youth | Rule 7(B) authority applies; sentence revised (not upheld as-is) |
| Whether youth and developmental differences require sentence reduction under Miller/Graham | Age not a sole basis to reduce given homicide convictions | Juvenile status requires consideration of immaturity and brain development | Court considered youth; reduction warranted under Miller/Graham framework and rebalancing of factors |
| What revised aggregate is appropriate given Fuller’s role as an actual shooter vs accomplice in Brown | Uniform treatment with Brown's sentence pending statutory considerations | Fuller as shooter warrants greater weight to aggravation | Allowed to tailor upward adjustment; Fuller receives 65+65 for murders and 20 for robbery, total 85 years |
Key Cases Cited
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile sentencing framework and maturity differences)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (juveniles have different culpability; constraints on extreme penalties)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (age-related culpability and brain development considerations)
- Anglemyer v. State, 868 N.E.2d 434 (Ind. 2007) (appellate review of sentencing under Rule 7(B))
- Carter v. State, 711 N.E.2d 835 (Ind. 1999) (earlier reductions for juvenile offenders)