Matthew Bryant v. State of Indiana, 984 N.E.2d 240

Background

Matthew Bryant was convicted of aggravated battery (Class B felony) and sentenced as a habitual offender in Bartholomew County, Indiana; the case proceeded to trial and sentencing in 2012–2013.
The June 4, 2011 incident in Bryant’s jail cell involved a fight with Roosevelt Crowdus, culminating in Bryant stabbing Crowdus in the ear with a pencil, causing permanent hearing loss.
Bryant was initially convicted of aggravated battery; the habitual offender determination was retried and Bryant was ultimately found to be an habitual offender, resulting in a 50-year aggregate sentence.
Bryant moved for a speedy trial under Indiana Criminal Rule 4(B); he was released on his own recognizance within 70 days of the request, but trial occurred after the 70-day window due to concomitant incarceration on another case.
The trial court admitted certain evidence (Crowdus’ statements to hospital staff and Bryant’s recorded phone call) over objections; the court later rejected some hearsay challenges and weighed Rule 403/404(b) considerations during sentencing, which Bryant challenges on appeal.
The court rejected Bryant’s challenges to sentencing, including alleged mitigating factors, and affirmed the 50-year sentence as appropriate under Rule 7(B) review.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy-trial rights violated under Rule 4(B)?	Bryant contends Rule 4(B) was violated because he remained incarcerated on another charge and trial occurred outside 70 days.	State asserts Rule 4(B) applies only when incarcerated on the charge sought for speedy trial, which was met here.	No rule violation; Cundiff controls, release within 70 days satisfied Rule 4(B) when on the target charge.
Admission of Crowdus’ hospital-statement testimony	Admission of Crowdus’ statement to Detective Roberts was hearsay and inadmissible.	The State argued Rule 801(d)(1)(C) identification and excited utterance theories supported admissibility.	Harmless error; statements were hearsay and not excited utterance, but cumulative independent evidence supported conviction.
Admission of Bryant’s jail-telephone recording	Recording contains hearsay from Bryant’s friend and coworker; should be excluded.	Recording primarily prompted Bryant to speak; not hearsay; probative of Bryant’s intent; Rule 403/404(b) balanced.	Not inadmissible hearsay; probative of intent; not unduly prejudicial; admissible under 404(b) for intent context.
Sufficiency of evidence on self-defense	State negates self-defense claim by proving Bryant provoked or willingly participated in the fight.	Bryant claimed self-defense; Crowdus offered a truce, and Bryant’s stabbing was not justified.	Evidence supports the jury’s finding that self-defense was not established beyond a reasonable doubt; conviction affirmed.
Sentencing abuse of discretion and appropriateness	Bryant argues mitigating factors (difficult childhood, mental illness) warrant lesser weight; court erred.	Defense did not raise mitigating factors timely; mental illness weighed minimally; sentence not disproportionate.	No abuse of discretion; mental illness not adequately mitigating; sentence within statutory and appellate standards; not inappropriate.

Key Cases Cited

Cundiff v. State, 967 N.E.2d 1026 (Ind. 2012) (guides Rule 4(B) applicability when incarcerated on unrelated charges; release on recognizance acceptable for speedy-trial timing)
Williams v. State, 669 N.E.2d 956 (Ind. 1996) (informant statements in recording not hearsay when used to prompt defendant to speak)
Weeks v. State, 697 N.E.2d 28 (Ind. 1998) (factors for evaluating weight of mental illness at sentencing)
Evans v. State, 727 N.E.2d 1072 (Ind. 2000) (admission of act evidence under Rule 404(b) when defendant raises self-defense)
Otte v. State, 967 N.E.2d 540 (Ind. Ct. App. 2012) (Crim. Rule 4 timing considerations in speedy-trial context)
Baer v. State, 866 N.E.2d 752 (Ind. 2007) (403 balancing for admissibility of jailhouse recording testimony)
Brim v. State, 624 N.E.2d 27 (Ind. Ct. App. 1993) (403/404(b) analysis guiding probative value vs. prejudice)