Marques Ridley v. State of Indiana (mem. dec.)
54A04-1701-CR-25
| Ind. Ct. App. | Sep 8, 2017Background
- In 2014 police conducted four controlled buys of purported heroin from Marques Ridley using a confidential informant (CI); purchases occurred Sept. 23, 24, 29, and 30.
- For each buy the CI was searched before and after, fitted with a transmitter, given buy money, and monitored by police; photographs and audio recordings were made.
- The CI turned over bindles obtained from Ridley after each buy; laboratory testing showed the Sept. 23 sample was heroin and the other three contained no controlled substances.
- Ridley was charged with one Level 5 felony dealing in a narcotic (heroin) and three Level 6 felonies for dealing in a substance represented to be controlled; tried by jury and convicted.
- At trial the State admitted the laboratory’s chain of custody report (generated by the lab’s computer system) through forensic scientist Jenna Crawford over Ridley’s authentication and hearsay objection.
- Ridley appealed, arguing (1) the chain of custody certificate was inadmissible hearsay/not authenticated and (2) insufficient evidence supported the convictions because the CI was allegedly inadequately searched/monitored and police did not see the exchange.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of lab chain-of-custody report | State: report is a business record and witness (Crawford) has functional knowledge to authenticate it | Ridley: report is hearsay, Crawford not records custodian, not properly authenticated; chain may be defective | Court: Admitted the report as a business record; Crawford had functional understanding and testimony showed lab process/system, satisfying authentication and Evid. R. 803(6)/901(b) |
| Sufficiency of the evidence for convictions | State: testimony, surveillance, pre/post searches, recordings, photos, and lab-positive bindle support convictions | Ridley: CI could have concealed items or money; exchanges not observed; buy money not recovered; CI credibility compromised | Court: Evidence—including controlled-buy procedures, audio/photos, and one heroin-positive bindle—was sufficient; appellate court will not reweigh credibility |
Key Cases Cited
- Wilson v. State, 765 N.E.2d 1265 (discussing abuse of discretion standard for evidentiary rulings)
- Smith v. State, 754 N.E.2d 502 (defining abuse of discretion)
- Whiteside v. State, 853 N.E.2d 1021 (appellate review considers evidence favoring trial ruling)
- Houston v. State, 957 N.E.2d 654 (functional understanding of record-keeping may authenticate business records)
- Rolland v. State, 851 N.E.2d 1042 (business-records authentication principles)
- Davenport v. State, 749 N.E.2d 1144 (authentication standard: sufficient evidence to support finding item is what proponent claims)
- In re Paternity of B.B., 1 N.E.3d 151 (absolute proof not required for authentication)
- Watson v. State, 839 N.E.2d 1291 (describing requirements and inference from properly conducted controlled buys)
- Rutherford v. State, 866 N.E.2d 867 (standard for reviewing sufficiency—no reweighing of evidence)
- Glotzbach v. State, 783 N.E.2d 1221 (consider only evidence favorable to judgment on sufficiency review)
- Stokes v. State, 922 N.E.2d 758 (burden for proving elements beyond reasonable doubt on appeal)
- Hitch v. State, 51 N.E.3d 216 (defendant may not raise new issues on appeal)