Jeffrey Z. Hayden v. State of Indiana
19 N.E.3d 831
| Ind. Ct. App. | 2014Background
- Hayden was convicted at trial of Burglary (Class B) and adjudicated a Habitual Offender.
- The burglary involved Ronald Pritchard’s life-estate residence in Mooresville, where Hayden removed items.
- Ronald had not actively lived there for about a year; belongings remained and utilities continued.
- Photographs and videos were taken by Ross Pierson, leading to Hayden’s detention.
- The State amended charges and Hayden was trialed January 2014, found guilty, and Habitual Offender status admitted.
- Judgment and 12-year burglary sentence were entered February 28, 2014, enhanced by habitual-offender status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Dwelling element sufficiency for burglary and residential entry | Hayden | Hayden | House satisfied the dwelling definition; sufficient evidence. |
| Trial court's refusal of proffered dwelling instruction | Hayden | Hayden | No abuse of discretion; instruction properly rejected. |
| Exclusion of hearsay evidence affecting intent | Hayden | Hayden | Hearsay rulings harmless error. |
| Charging information sufficiency and notice | Hayden | Hayden | Not fundamentally deficient; information adequate. |
| Double jeopardy/merger principles and judgment entries | Hayden | Hayden | Residential Entry vacated; Theft not barred; remand for judgment-vacatur decisions. |
Key Cases Cited
- Griffin v. State, 439 N.E.2d 160 (Ind. 1982) (need property description in theft-related charges; notice to defend)
- White v. State, 846 N.E.2d 1026 (Ind. Ct. App. 2006) (dwelling vs. habitation distinction; enduring protections)
- Watt v. State, 446 N.E.2d 644 (Ind. Ct. App. 1983) (dwelling defined as home despite absence at time of burglary)
- Middleton v. State, 391 N.E.2d 657 (Ind. Ct. App. 1979) (ownership and return intent impact on dwelling character)
- Ferrell v. State, 565 N.E.2d 1070 (Ind. 1991) (habitation-related considerations in burglary)