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Jemery Alan Riddle v,. State of Indiana (mem. dec.)
27A05-1606-CR-1360
| Ind. Ct. App. | May 30, 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Jemery Alan Riddle v,. State of Indiana (mem. dec.)
Court Name: Indiana Court of Appeals
Date Published: May 30, 2017
Docket Number: 27A05-1606-CR-1360
Court Abbreviation: Ind. Ct. App.