Marq Hall v. State of Indiana
2015 Ind. LEXIS 575
| Ind. | 2015Background
- Hall was convicted of class A felony child molesting after a jury trial in Indiana.
- The offense involved the 2012 incident in which M.T. testified Hall molested and raped her while her mother, A.D., was at work.
- Hall sought to compel A.D. to answer a deposition question about a prior Kentucky incident; the trial court denied the motion.
- The trial court granted a Rule 412 in limine prohibiting admission of prior sexual conduct of the victim, limiting exploration of the Kentucky incident.
- A recording of Hall and A.D.’s phone call was admitted for impeachment but the court later excluded the relevant portions; the Court of Appeals vacated and Hall’s conviction was affirmed as harmless, which the Supreme Court upheld.
- Dissent argued the cross-examination right was violated and reversal was required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of compelled deposition testimony violated confrontation rights | Hall: denial violated Sixth Amendment cross-examination rights | State: Rule 412 limits and error harmless | Harmless beyond a reasonable doubt |
| Whether excluding the phone call violated confrontation rights | Hall: exclusion violated Sixth Amendment | State: door opened but error harmless | Harmless beyond a reasonable doubt |
Key Cases Cited
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (five-factor harmless-error framework for confrontation errors)
- Chapman v. California, 386 U.S. 18 (U.S. 1967) (harmless-error standard for constitutional violations)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (cross-examination essential for reliability of factfinding)
- Koenig v. State, 933 N.E.2d 1271 (Ind. 2010) (harmless-error analysis for confrontation violations)
- Gilliam v. State, 270 Ind. 71, 383 N.E.2d 297 (Ind. 1978) (door-opening exception to admissibility under limiting rules)