Lee Travis Griffin v. State of Indiana
16 N.E.3d 997
| Ind. Ct. App. | 2014Background
- Griffin was convicted by jury of robbery (Class A), burglary (Class A), and felony murder; aggregate sentence 115 years.”,
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for robbery | Griffin relied on lack of participation; accomplice liability suffices | Griffin argues no on-scene participation or knowledge | Sufficient evidence supports accomplice liability and robbery conviction |
| Admissibility of autopsy photographs | Photos aided proving Sandra's death; not unduly prejudicial | Photographs were gruesome and prejudicial; waived | Waived, but admission proper under caselaw; not abuse of discretion |
| Proffered jury instruction (reasonable theory of innocence) | Hampton requires instruction when only circumstantial evidence supports actus reus | Direct evidence exists; Hampton not required | No abuse; direct evidence supports instruction not required |
Key Cases Cited
- Pillow v. State, 986 N.E.2d 343 (Ind. Ct. App. 2013) (standard for sufficiency; review of probative evidence)
- Wilson v. State, 455 N.E.2d 1120 (Ind. 1983) (accomplice liability imputation of acts to principal)
- Collier v. State, 470 N.E.2d 1340 (Ind. 1984) (accomplice liability, acts of one imputable to all)
- Johnson v. State, 605 N.E.2d 762 (Ind. Ct. App. 1992) (accomplice liability “common design” concept)
- Bruno v. State, 774 N.E.2d 880 (Ind. 2002) (Bruno factors for accomplice relationship)