Jaron D. Johnson v. State of Indiana (mem. dec.)
18A02-1701-CR-169
| Ind. Ct. App. | Sep 18, 2017Background
- On Feb. 9, 2016, Jaron D. Johnson and an accomplice forcibly entered a Muncie residence; Johnson wore a bandana and the accomplice, masked, pointed an AR-15 at a pregnant woman and two children and demanded a safe.
- Johnson collapsed after an apparent seizure during the burglary; the accomplice took the safe and a handgun and fled, leaving Johnson at the scene.
- Police arrived, obtained a Miranda waiver, and took Johnson’s statement; portions of his post-arrest remarks (expressing a refusal to answer for fear of self-incrimination) were later redacted at trial.
- Johnson was charged with Level 2 felony burglary while armed; a jury convicted him as charged.
- At sentencing the court found aggravators (offense committed on bond; prior juvenile adjudications involving firearms) and mitigators (age, first felony, family support, substance issues, prison work record) and imposed a 17-year sentence (14 executed, 3 suspended to probation).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Johnson) | Held |
|---|---|---|---|
| Whether trial court erred by admitting Johnson’s post-arrest statements (silence/refusal to answer) | Admission proper after redaction; any error was harmless given other evidence | Admission violated Doyle v. Ohio — use of post-Miranda silence impermissible and prejudicial | Court: Any Doyle error was harmless beyond a reasonable doubt (overwhelming evidence of guilt; only brief general references remained) |
| Whether 17-year sentence is inappropriate under Ind. Appellate Rule 7(B) | Sentence reasonable given gravity of armed home invasion, threat to pregnant woman and children, and prior juvenile weapon adjudications | Sentence excessive given seizure limited participation, lack of direct weapon use, no physical injuries, and youth/mitigators | Court: Sentence not inappropriate in light of offense seriousness and defendant’s character; affirmed |
Key Cases Cited
- Doyle v. Ohio, 426 U.S. 610 (1976) (post-Miranda silence generally cannot be used against a defendant)
- Wainwright v. Greenfield, 474 U.S. 284 (1986) (Doyle principles extend beyond impeachment to prosecution’s case-in-chief in some contexts)
- Sobolewski v. State, 889 N.E.2d 849 (Ind. Ct. App. 2008) (harmless-error factors for Doyle violations)
- Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (scope and purpose of Rule 7(B) appellate review of sentence)