Matthew Edmonds v. State of Indiana
86 N.E.3d 414
| Ind. Ct. App. | 2017Background
- On June 8, 2015, Matthew Edmonds was seen shoplifting at a Wal‑Mart and left in a vehicle; officers identified the vehicle and began pursuit.
- Edmonds drove at very high speeds, ran red lights, and evaded officers; officers intermittently terminated the high‑speed chase for safety but continued to track him without lights and sirens.
- While still being followed, Edmonds ran a red light and collided with a truck, killing the driver (Donna Niblock) and seriously injuring two passengers; Edmonds fled on foot and was captured.
- Jury convicted Edmonds of multiple offenses including one count of Level 3 felony resisting law enforcement causing death and two counts of Level 5 resisting causing serious bodily injury, plus multiple leave‑the‑scene and other counts.
- Trial court merged and later sentenced Edmonds to an aggregate of 25 years; on appeal the court sua sponte found double jeopardy problems with multiple convictions based on a single course of conduct and vacated several convictions, affirming only one resisting conviction and one leaving‑the‑scene conviction, and remanding for resentencing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Edmonds) | Held |
|---|---|---|---|
| Whether multiple resisting‑law‑enforcement convictions (death + two serious injury counts) violate double jeopardy | Multiple convictions are permissible because separate victims suffered different harms | All resisting counts arose from a single act/incident so multiple convictions and punishments are barred by double jeopardy | Vacated the two Level 5 resisting convictions; only one resisting conviction may stand (double jeopardy bars multiple punishments for the single conduct) |
| Whether multiple leave‑the‑scene convictions (one death + injuries + misdemeanor) violate double jeopardy | Each injured/deceased person supports a separate count | Statute and analogous precedent treat leaving one accident as one offense regardless of number injured | Vacated three lesser leave‑the‑scene convictions; one conviction for leaving the scene may remain |
| Whether evidence was sufficient to support conviction for Level 3 resisting causing death where officers had turned off lights/sirens before crash | Officers were still pursuing/tracking Edmonds and had earlier identified themselves; driver continued fleeing so resisting element satisfied | Once lights/sirens were turned off before the crash, Edmonds was not actively resisting at time of collision | Affirmed: evidence sufficient—Edmonds continued to flee while officers monitored him, so he knowingly fled from law enforcement and caused death |
| Whether remand for resentencing was required and permissible | Trial court should vacate duplicative counts and resentence within original aggregate constraints | Edmonds argued errors required relief | Court remanded for resentencing and noted trial court may adjust individual terms so long as aggregate does not exceed original sentence |
Key Cases Cited
- Goldsberry v. State, 821 N.E.2d 447 (Ind. Ct. App.) (standard for reviewing double jeopardy/convictions)
- Davis v. State, 691 N.E.2d 1285 (Ind. Ct. App.) (double jeopardy principles under state and federal constitutions)
- Richardson v. State, 717 N.E.2d 32 (Ind.) (protection against multiple punishments in a single trial)
- Wharton v. State, 42 N.E.3d 539 (Ind. Ct. App.) (actual‑evidence test: offenses arising from same action support double jeopardy analysis)
- Wood v. State, 999 N.E.2d 1054 (Ind. Ct. App.) (single‑accident rule for leave‑the‑scene convictions)
- Spears v. State, 412 N.E.2d 81 (Ind. Ct. App.) (visual/audible order to stop and sufficiency for resisting when defendant flees)
- Binkley v. State, 654 N.E.2d 736 (Ind.) (standard for sufficiency review)
- Drane v. State, 867 N.E.2d 144 (Ind.) (credibility not reweighed on sufficiency review)
- Owens v. State, 742 N.E.2d 538 (Ind. Ct. App.) (approach to selecting which convictions to vacate when double jeopardy implicates multiple counts)
- Guffey v. State, 42 N.E.3d 152 (Ind. Ct. App.) (trial court sentencing flexibility on remand so long as aggregate not increased)