James F. Griffith v. State of Indiana
2016 Ind. LEXIS 671
| Ind. | 2016Background
- Victim Duwayne Lindsey (81) was killed; guns, coins, and cash taken from his home; body discovered in decayed condition; van later seized with multiple of Lindsey’s items and blood evidence.
- James Griffith and Lacy Bradley were implicated; Bradley testified Griffith signaled and participated in the murder and robbery.
- Griffith was arrested in Kentucky on unrelated charges, extradited to Indiana March 11, 2013, and tried April 11, 2014; convicted of murder, robbery, and conspiracy; sentenced to LWOP plus concurrent terms.
- Griffith proceeded largely pro se with standby counsel after dismissing appointed attorneys.
- On appeal Griffith challenged discovery procedures, speedy-trial timing, denial of publicly funded experts, separation-of-witnesses violations, admission of entomologist testimony, validity of the van search warrant, and sufficiency of the evidence.
- The Indiana Supreme Court affirmed in all respects, finding no reversible error on any claim.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Griffith) | Held |
|---|---|---|---|
| Due process/discovery access | State provided disc contents in printed form; defendant had standby counsel and means to request more or continuance | State gave discovery only on an inaccessible electronic disc; printed box lacked some photos, denying meaningful access | No due process violation; no record proof box omitted materials and standby counsel/continuance available |
| Speedy trial (Crim. R. 4 & Const.) | Clock begins on Indiana arrest/extradition (Mar 11, 2013); delays largely caused/waived by Griffith | Clock should start at Kentucky arrest (Jul 25, 2012); 20‑month delay violated speedy-trial rights | Clock began at Indiana arrest; most delay attributable to Griffith’s continuances; no violation |
| Publicly funded experts (DNA, blood spatter) | Trial court properly denied funds where defendant failed to show need, identify experts, or provide cost/qualifications | Needed experts to challenge State’s DNA and blood-scene inferences | Denial affirmed—Griffith failed to meet burden to obtain publicly funded experts |
| Separation of witnesses (opening statements) | Allowing witnesses to hear openings (briefly) did not prejudice defendant and he voiced no contemporaneous objection | Violation of separation order; fundamental error because witnesses heard State’s openings | No fundamental error—no timely objection and no showing of prejudice |
| Admission of entomologist testimony | State gave adequate notice (supplemental discovery + report) and did not deliberately conceal witness | Notice was insufficient and admission was prejudicial | Admission proper—Dr. Haskell was disclosed months before trial and no deliberate concealment shown |
| Van search warrant validity | Warrant specifically described van (VIN, plate) and listed items to be seized; not overbroad | Warrant was general and violated search‑and‑seizure protections | Warrant upheld as sufficiently specific under Federal and Indiana Constitutions |
| Sufficiency of evidence for convictions | Eyewitness testimony, DNA linking Griffith to glove/shoes/garments, possession of victim’s property support convictions | Bradley acted alone; evidence insufficient to prove Griffith guilty | Evidence was overwhelming; convictions supported by reasonable inferences |
Key Cases Cited
- Weatherford v. Bursey, 429 U.S. 545 (U.S. 1977) (Fourteenth Amendment does not create broad discovery right for defendants)
- Bounds v. Smith, 430 U.S. 817 (U.S. 1977) (prisoners must have meaningful access to courts via law libraries or assistance)
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four‑factor balancing test for speedy trial claims)
- Sweeney v. State, 704 N.E.2d 86 (Ind. 1998) (rule on when arrest outside Indiana becomes effective for Rule 4 timing)
- Flores v. State, 485 N.E.2d 890 (Ind. 1985) (continuance is remedy for belated disclosures)
- Scott v. State, 593 N.E.2d 198 (Ind. 1992) (trial court discretion on providing experts at public expense)
- Tidwell v. State, 644 N.E.2d 557 (Ind. 1994) (defendant bears burden to justify appointment of experts)
- Taylor v. State, 676 N.E.2d 1044 (Ind. 1997) (abuse-of-discretion standard for admitting belatedly disclosed witnesses; deliberate concealment required for reversal)
- Overstreet v. State, 783 N.E.2d 1140 (Ind. 2003) (search warrant specificity requirement under Indiana Constitution)
- Gibson v. State, 51 N.E.3d 204 (Ind. 2016) (standard for sufficiency of the evidence review)