Martin Meehan v. State of Indiana, 7 N.E.3d 255

On May 3, 2011, employees discovered forced entry at O.J.S. Building Services; an overhead door panel was removed and interior doors were off hinges; laptops and cash were missing.
A black glove was found just inside the overhead door near the point of entry; employee testified the glove was not there when he locked the building the prior evening.
DNA testing of a stain on the glove produced a match to Martin Meehan; no other DNA was recovered from the glove.
Meehan was arrested in December 2011 in possession of bolt cutters, a screwdriver, a chisel, pocketknife, and Allen keys; he denied involvement; a DNA swab from Meehan matched the glove DNA.
A jury convicted Meehan of class C felony burglary; the trial court later found him a habitual offender and imposed an aggregate 13-year sentence (5 years burglary + 8 years habitual enhancement).
The Court of Appeals reversed the burglary conviction as insufficient (concluding the glove could have obtained Meehan’s DNA at another time); the Indiana Supreme Court granted transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove burglary (DNA on glove)	State: glove with Meehan’s DNA found steps from point of entry, no legitimate access, and Meehan had tools — jury could reasonably infer he was the burglar	Meehan: DNA transfer is easy; glove could have been lost, borrowed, or contaminated earlier; presence of DNA alone is insufficient	Affirmed — evidence (glove with Meehan’s DNA at point of entry, lack of authorization, and possession of tools) permitted a reasonable jury inference of guilt beyond a reasonable doubt
Consecutive habitual-offender enhancements	State: enhancements valid as imposed	Meehan: trial court erred in ordering this habitual enhancement consecutive to an earlier enhancement	Remanded — trial court must order the habitual enhancement in this case to run concurrent with the other enhancement (consecutive habitual enhancements are prohibited)
Trial court’s timeliness to amend charging information	State: issue waived for failure to include complete record on appeal	Meehan: charging information amended after statutory deadline	Waived — appellant failed to provide transcript of amendment hearing, so appellate review forfeited

Drane v. State, 867 N.E.2d 144 (Ind. 2007) (standard for reviewing sufficiency of the evidence)
Mediate v. State, 498 N.E.2d 391 (Ind. 1986) (fingerprints and inferences about lawful access and location relevance)
Shuemak v. State, 258 N.E.2d 158 (Ind. 1970) (footprints and prints found at crime scene may prove identity)
Breaston v. State, 907 N.E.2d 992 (Ind. 2009) (trial courts may not order consecutive habitual-offender enhancements)