Joseph Matheny v. State of Indiana
983 N.E.2d 672
| Ind. Ct. App. | 2013Background
- Matheny was arrested after being found in Dedinsky’s stolen car in a ditch; he gave inconsistent statements about involvement.
- Police questioned Matheny about his address to verify ID information; he lived at Wheeler Mission close to the crime scene.
- Matheny was initially questioned custodially; the court suppressed statements after intake but allowed identifying information.
- Officer Klonne asked for Matheny’s address multiple times; Matheny ultimately denied living at the ID address.
- The State charged Matheny with class D felony auto theft; at trial the statement about Wheeler Mission was admitted.
- The jury found Matheny guilty; Matheny appeals alleging Miranda violation and instructional error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of residence statement under Miranda | State argues addressing ID information is non-Miranda routine. | Matheny contends the question was custodial interrogation and testimonial. | Admissible; questions outside Miranda but routine identifying information. |
| Error in refusing Instruction No. 1 on presumption of innocence | State contends instruction incomplete but not reversible. | Matheny argues instruction rightly required innocence-preserving interpretation. | Trial court did not abuse in refusing No.1. |
| Error in refusing Instruction No. 6 on fitting evidence to innocence | State asserts other instructions adequately stated the principle. | Matheny argues No.6 accurately stated presumption principles. | Trial court abused in refusing No.6, but error was harmless. |
| Harmless error analysis re: instructional error | State's position on harmlessness. | Matheny argues error affected verdict. | Error harmless given overwhelming evidence and proper instructions. |
Key Cases Cited
- Robey v. State, 454 N.E.2d 1221 (Ind. 1983) (presumption of innocence instruction required if requested; incomplete language addressed)
- Simpson v. State, 915 N.E.2d 511 (Ind. Ct. App. 2009) (incomplete presumption instruction analyzed; companion paragraph required)
- Lee v. State, 964 N.E.2d 859 (Ind. Ct. App. 2012) (refusal of presumption instruction reviewed for reversible error)
- Muniz, 496 U.S. 582 (U.S. 1990) (routine booking questions outside Miranda scope; custodial interrogation delineation)
- Loving v. State, 647 N.E.2d 1123 (Ind. 1995) (identification/biographical questions exceptions to Miranda)
- Castillo-Aguilar v. State, 962 N.E.2d 667 (Ind. Ct. App. 2012) (purpose of information sheet; interrogation considerations)