Joe M. Meyers v. State of Indiana (mem. dec.)
30A01-1609-PC-2265
| Ind. Ct. App. | Oct 18, 2017Background
- Victim Katrina Miller was found shot in a cornfield; investigation tied four hotel residents (Meyers, Westbrook, Gonzales, Miller) to a trip from their hotel to the cornfield the morning of the killing.
- Two hotel residents (Muse and Webster) reported overhearing Gonzales describe the killing; surveillance and hotel records corroborated the group left together and returned without Miller.
- Police obtained warrants and searched Meyers’ hotel room (unfired .380 rounds found), vehicle (handguns/shotgun recovered), and a storage unit (disassembled .380 with slide matched to casing at scene).
- Meyers was convicted by a jury of murder and Level 3 felony kidnapping; sentenced to 60 years (murder) + 15-year habitual enhancement (aggregate 75 years).
- Meyers pursued post-conviction relief (PCR) after invoking Davis/Hatton; PCR court granted State summary disposition and denied relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity/admission of search warrants (hotel room, vehicle, storage unit) | Warrant affidavits supplied probable cause via corroborated citizen informants and jailhouse tip; searches lawful and evidence admissible | Meyers argued hearsay/unreliable informants and omissions (vehicle affidavit) rendered warrants invalid and evidence inadmissible | Court upheld warrants: hotel room and storage unit affidavits had sufficient corroboration; vehicle search admissible at least under the Leon good-faith exception |
| Sufficiency of evidence for murder and kidnapping | State: direct confession to co-defendant, surveillance, cell records, ammunition and matched gun parts, and other circumstantial evidence proved intent and accomplice liability | Meyers argued lack of proof he knowingly/intentionally killed Miller or that he was armed/participated in kidnapping | Court found sufficient evidence for both convictions (confession, forensic links, accomplice factors supported kidnapping) |
| Judicial bias | State: judge’s rulings were lawful procedural decisions | Meyers: adverse pretrial suppression ruling showed judge bias requiring recusal | Court held mere adverse rulings are insufficient to show bias; no evidence judge expressed impermissible opinion |
| Ineffective assistance of counsel (trial/appellate) | Meyers claimed counsel failed to object to lack of counsel at arraignment and failed to seek change of judge | State: Meyers waived counsel by proceeding pro se; counsel appointed and acted within scope; appellate claim moot after Davis/Hatton remand | PCR court and appellate court found no deficient performance or prejudice; claims fail |
| PCR summary disposition / findings | Meyers argued PCR court failed to make specific findings on all issues and improperly granted summary disposition | State moved for summary disposition arguing no genuine issue of material fact and that claims (e.g., appellate ineffectiveness) were moot | Court treated State motion under PCR 1(4)(g), found issues sufficiently presented, no disputed facts requiring hearing, and affirmed summary denial of PCR relief |
Key Cases Cited
- Roche v. State, 690 N.E.2d 1115 (Ind. 1997) (standard of review for evidentiary rulings)
- Casady v. State, 934 N.E.2d 1181 (Ind. Ct. App. 2010) (probable cause and magistrate’s practical decision)
- Spillers v. State, 847 N.E.2d 949 (Ind. 2006) (corroboration of anonymous informant by police investigation)
- Pawloski v. State, 380 N.E.2d 1230 (Ind. 1978) (reliability of cooperative citizen informants)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-the-circumstances test for probable cause)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance two-prong test)
- Vitek v. State, 750 N.E.2d 346 (Ind. 2001) (factors for accomplice liability)