Lawrence Gyamfi v. State of Indiana
15 N.E.3d 1131
| Ind. Ct. App. | 2014Background
- Gyamfi was convicted in Hancock County of fraud (Count I), theft (Count II), and forgery (Count III).
- Boone County previously suppressed evidence from an unlawful search of Gyamfi and co-defendant Asiedu; charges were dismissed in Boone County.
- A Hancock County Hancock transaction receipt tied to Whitmer’s Discover Card surfaced after the Boone County search.
- Detectives and store security personnel obtained surveillance stills and card-account data related to the Hancock County Transaction.
- The trial court admitted the Hancock County surveillance video and related testimony over suppression objections.
- The appellate court reversed, holding the evidence derived from the illegal Boone County search violated Indiana Constitution Article I, Section 11 and was inadmissible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admission of derivative evidence from an unlawful search violated Article I, Section 11. | State argues attenuation or inevitable discovery save evidence. | Gyamfi contends the evidence is fruit of the poisonous tree and inadmissible. | Yes; admission was improper and reversed. |
Key Cases Cited
- Hanna v. State, 726 N.E.2d 384 (Ind. Ct. App. 2000) (fruit of the poisonous tree doctrine applies to derivative evidence)
- Trotter v. State, 933 N.E.2d 572 (Ind. Ct. App. 2010) (Indiana constitutional protections exceed Fourth Amendment in attenuation analysis)
- Shultz v. State, 742 N.E.2d 961 (Ind. Ct. App. 2001) (inevitable discovery not adopted under Indiana Constitution)
- Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (attenuation doctrine exists under Fourth Amendment but not Indiana Constitution)
- Clark v. State, 994 N.E.2d 252 (Ind. 2013) (inevitable discovery exception can apply if proved by preponderance)