Jemery Alan Riddle v,. State of Indiana (mem. dec.)
27A05-1606-CR-1360
| Ind. Ct. App. | May 30, 2017Background
- Defendant Jeremy Alan Riddle was tried for murder, unlawful possession of a firearm by a serious violent felon (Level 4), and theft (Level 6) after shooting neighbor Wendell Donaldson in the back of the head and stealing property.
- Evidence included decomposed body with a 9mm spent casing at the scene, the victim’s pockets turned inside out, missing phone and pills, and Riddle’s fingerprints/DNA on a glass at the scene and a 9mm handgun found near Riddle’s residence that matched the spent casing.
- Riddle sold some stolen items to a pawn shop shortly after the killing and made statements admitting he had done something "bad" to obtain money for his wife’s bond.
- At trial Riddle objected to admission of multiple crime-scene photographs and autopsy photographs as unduly prejudicial and, for autopsy photos, showing the body in an altered condition. The trial court admitted the challenged exhibits over objection.
- Jury convicted Riddle on all counts; aggregate sentence 77 years. Riddle appealed, arguing the photo admissions denied him a fair trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of crime‑scene photographs (gruesome/repetitive) | Photos were relevant to wound, body position, decomposition, and theft motive; showed angles and scene layout important to State’s case | Photos were graphic, repetitive, and some not referenced in testimony, so probative value was substantially outweighed by unfair prejudice | Court upheld admission: photos were relevant and aided the jury; one potentially redundant photo (Ex. 24) would be harmless error given other evidence of guilt |
| Admissibility of autopsy photographs (body altered) | Minimal, necessary manipulation by pathologist to show entry wound and stippling; alteration explained to jury, and photos demonstrated testimony | Autopsy photos showed the body in an altered/manipulated state and thus were inadmissible or unduly prejudicial | Court upheld admission: manipulation was minor and done to demonstrate injuries; probative value not substantially outweighed by prejudice |
Key Cases Cited
- Halliburton v. State, 1 N.E.3d 670 (Ind. 2013) (standard for admitting photographs and autopsy-photo considerations)
- Woods v. State, 677 N.E.2d 499 (Ind. 1997) (crime‑scene and body photos admissible if relevant and aid jury)
- Cutter v. State, 725 N.E.2d 401 (Ind. 2000) (photograph’s probative value must not be substantially outweighed by unfair prejudice)
- Amburgey v. State, 696 N.E.2d 44 (Ind. 1998) (even gory photos admissible if relevant to material issue)
- Corbett v. State, 764 N.E.2d 622 (Ind. 2002) (harmless error test for evidentiary rulings)
- Hoglund v. State, 962 N.E.2d 1230 (Ind. 2012) (substantial independent evidence can render erroneous admission harmless)
- Swingley v. State, 739 N.E.2d 132 (Ind. 2000) (autopsy photos generally inadmissible if body shown in altered condition, but limited alteration allowed to demonstrate testimony)
- Allen v. State, 686 N.E.2d 760 (Ind. 1997) (concern that autopsy manipulation may be imputed to defendant)
