Jeffrey Leonard Camp v. State of Indiana (mem. dec.)
79A02-1707-CR-1676
| Ind. Ct. App. | Dec 20, 2017Background
- Camp, divorced from Julie Camp, returned to her residence at midnight on Oct 7, 2016; Julie was away with a friend and their minor daughter M.C. was babysitting.
- M.C. observed Camp at the door; she feared him and texted Julie for help, signaling that Camp was not supposed to be there.
- Camp entered Julie’s house with M.C. having previously communicated to Julie’s friend about the intrusion; Julie later arrived, called the police, and the incident was investigated.
- Camp sent numerous text messages to Julie after the incident, including threats and inflammatory statements over hours and into the next day.
- In May 2017 Camp moved to suppress certain statements; in January 2017 he gave a statement at the prosecutor’s office without an attorney present.
- The State charged Camp with residential entry as a level 6 felony; he was convicted and sentenced to 730 days with half served and half on community corrections.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the January 9 meeting statements were admissible | State argued statements were not plea negotiations and admissible | Camp contends statements were plea negotiations; improper admission | Admissible but harmless error; not plea negotiations |
| Whether the evidence suffices to sustain the conviction | State asserts sufficient evidence via M.C.’s testimony and surrounding facts | Camp challenges credibility and sufficiency, citing dubiosity | Sufficiency affirmed; permissive inferences support guilt |
| Whether the sentence is inappropriate given offense and character | State emphasizes aggravating factors and offense severity | Camp claims lesser conduct, good character, and mitigated factors | Sentence affirmed; not inappropriate |
Key Cases Cited
- Palilonis v. State, 970 N.E.2d 713 (Ind. Ct. App. 2012) (evidentiary rulings reviewed for abuse of discretion)
- Hoglund v. State, 962 N.E.2d 1230 (Ind. Ct. App. 2012) (harmless error when cumulative or non-prejudicial)
- Love v. State, 761 N.E.2d 806 (Ind. 2002) (incredible dubiosity narrow exception; rarely used)
- Gonzalez v. State, 929 N.E.2d 699 (Ind. 2010) (plea negotiations criteria; admissibility guidance)
- Martin v. State, 537 N.E.2d 491 (Ind. 1989) (unilateral offer of evidence not protected)