Julie Jean Wright v. State of Indiana (mem. dec.)
73A04-1702-CR-256
Ind. Ct. App.Dec 11, 2017Background
- In July 2014 a confidential informant arranged a controlled buy of one-half ounce (13.9 g) of methamphetamine for $850 from Jovina Cueto; narcotics officers surveilled and recorded the transaction.
- Julie Jean Wright (eight months pregnant) drove to the buy location with her 15-year-old (also pregnant) daughter in the front seat and Cueto in the rear; Wright had a history of giving Cueto rides for money.
- After the sale, officers stopped Wright’s vehicle, found $800 of the buy money on the rear floorboard, and later recovered a bindle of methamphetamine (1.09 g) in Wright’s black purse along with ID in her name.
- A K-9 alerted to the impounded vehicle, officers obtained a search warrant, and forensic testing confirmed both seized substances were methamphetamine.
- Wright was charged with dealing methamphetamine (Level 2), possession in presence of a child (Level 3), and neglect of a dependent (Level 5); the jury convicted and the court imposed a 15-year executed sentence (3 years suspended).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support convictions (including accomplice theory) | State: Evidence (texts, calls, meeting with supplier, fronted drugs, buy coordination, money recovered, drugs in Wright’s purse, presence of minor) supports convictions beyond a reasonable doubt | Wright: She only provided a ride and attempted to sell her dog; facts do not prove knowing delivery/possession or neglect | Affirmed — the evidence and reasonable inferences supported convictions; appellate court will not reweigh evidence |
| Fundamental error in admitting lab report (State’s Exhibit 20) after lab mislabeling of item tags | State: Exhibit admissible; technician testified weights/tests were correct despite swapped tags; defense cross-examined | Wright: Mislabeling transposed weights between items; failure to object at trial — argues admission was fundamental error | No fundamental error — court found mislabeling explained, trial counsel cross-examined, and defendant failed to show a fair trial was impossible |
Key Cases Cited
- Leonard v. State, 80 N.E.3d 878 (Ind. 2017) (standard for reviewing sufficiency of the evidence)
- Specht v. State, 838 N.E.2d 1081 (Ind. Ct. App. 2005) (accomplice liability is a separate basis of liability, not a separate crime)
- Guilmette v. State, 14 N.E.3d 38 (Ind. 2014) (admissibility of evidence rests within trial court's discretion)
- Thomas v. State, 81 N.E.3d 621 (Ind. 2017) (standard for abuse of discretion in evidentiary rulings)
- Harris v. State, 76 N.E.3d 137 (Ind. 2017) (defining fundamental error as narrow exception to waiver)
- Gibson v. State, 51 N.E.3d 204 (Ind. 2016) (context on the heavy burden to show fundamental error)
- Taylor v. State, 687 N.E.2d 606 (Ind. Ct. App. 1997) (failure to object waives error absent fundamental error)
