Joseph Matheny v. State of Indiana
987 N.E.2d 1169
Ind. Ct. App.2013Background
- Appellant-Defendant Joseph Matheny was convicted in Marion Superior Court of a class D felony auto theft, resulting in an appeal to the Indiana Court of Appeals.
- The State petitioned for rehearing after the court previously affirmed, focusing on whether the trial court’s refusal of Matheny’s jury instruction on the presumption of innocence was reversible error.
- Matheny tendered Instruction No. 6, which urged jurors to fit the evidence to the presumption of innocence and to reconcile conflicting testimony if possible.
- Robey v. State and Farley v. State set the standard that the presumption of innocence must be conveyed to the jury and that the instruction should guide the jury accordingly.
- The Santiago and Albores opinions analyzed similar presumption-instruction issues but involved more explicit instructions directing the jury to reconcile the evidence with the presumption of innocence.
- The court ultimately clarifies that its holding does not conflict with Santiago/Albores and reaffirms that the trial court abused its discretion in not adequately conveying the presumption of innocence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court err by denying Matheny’s presumption of innocence instruction? | Matheny | State | Yes, error occurred; instruction not adequately conveyed presumption |
| Was the instructional error harmless beyond a reasonable doubt given the totality of the circumstances? | Matheny | State | No; error not harmless; warrants reversal/affirmation of original ruling |
Key Cases Cited
- Robey v. State, 454 N.E.2d 1221 (Ind. 1983) (presumption of innocence must be conveyed; instruction to reconcile evidence if possible)
- Farley v. State, 127 Ind. 419, 26 N.E. 898 (Ind. 1891) (presumption of innocence instruction required)
- Simmons v. State, 385 N.E.2d 225 (Ind. App. 1979) (presumption and reconciliation guidance not adequately conveyed by circumstantial-evidence instruction alone)
- Lee v. State, 964 N.E.2d 859 (Ind. Ct. App. 2012) (presumption-in-innocence instruction must be explicit; ambiguity in denials)
- Kentucky v. Whorton, 441 U.S. 786 (U.S. 1979) (informational standard on evaluating presumption-related jury instructions)