Leandrew Beasley v. State of Indiana, 2016 Ind. LEXIS 26

On Aug. 2–3, 2012, James Allen told Gerald Beamon that Allen had shot Leandrew Beasley in the face during an earlier altercation; Beasley had a contemporaneous facial gunshot wound and was treated at a hospital.
The next day Allen showed Beamon photos of men at the prior fight, including Leandrew and his brother James; later that day a shooting killed Allen and wounded Beamon, who identified Leandrew and James as shooters.
Leandrew and James Beasley were charged with murder and attempted murder; Leandrew also convicted of unlawful possession of a firearm by a serious violent felon.
At trial the court admitted Beamon’s testimony recounting Allen’s prior statements that he shot Beasley, over hearsay objections, under Indiana Evidence Rule 804(b)(3) (statement against penal interest).
The Court of Appeals deemed admission erroneous but harmless (relying on eyewitness ID); the Indiana Supreme Court granted transfer to review admissibility under Rule 804(b)(3) and affirmed the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Allen’s out‑of‑court statements to Beamon were admissible under Ind. Evidence Rule 804(b)(3) (statement against interest)	State: statements were against Allen’s penal interest and thus admissible; trial court acted within discretion.	Beasley: Allen’s statements described self‑defense (not criminal), were not sufficiently against penal interest, and thus inadmissible hearsay.	Court: admissible — shooting admission had sufficient tendency to expose Allen to civil/criminal liability; trial court did not abuse discretion.
Whether admission of the hearsay was reversible error because it supplied the only evidence of motive	Beasley: admission was harmful because motive evidence was essential and the only evidence of motive was the hearsay.	State: corroborating evidence and identifications reduce risk of prejudice.	Court: agreed that erroneous admission would be harmful in principle, but found admission was not erroneous and there was corroboration supporting reliability.

Jervis v. State, 679 N.E.2d 875 (Ind. 1997) (explains limits on admitting statements as against penal interest where statements are vague or only cast suspicion)
Camm v. State, 908 N.E.2d 215 (Ind. 2009) (rejects admission where declarant’s remarks did not amount to admissions or tend to subject him to criminal liability)
Nicholson v. State, 963 N.E.2d 1096 (Ind. 2012) (standard that trial courts have wide discretion on admissibility of evidence)
Pierce v. State, 29 N.E.3d 1258 (Ind. 2015) (appellate review considers evidence favorable to the ruling)
Kiefer v. State, 761 N.E.2d 802 (Ind. 2002) (absence of motive can be a significant exculpatory factor)
Williamson v. United States, 512 U.S. 594 (1994) (discussion of statement‑against‑interest rationale and trial judge’s role in evaluating admissibility)