Matthew Williams v. State of Indiana (mem. dec.)
49A04-1703-CR-620
| Ind. Ct. App. | Nov 7, 2017Background
- Around 2:30 a.m., deputies observed Matthew Williams driving at a high rate of speed, erratically, crossing lane lines, intermittently braking, and running a red light; they stopped him.
- Deputies observed glossy, bloodshot eyes, slurred speech, and a strong smell of alcohol; Williams failed three field sobriety tests (HGN, walk-and-turn, one-leg stand) and refused chemical testing.
- Williams was arrested and charged with Operating a Vehicle While Intoxicated, Endangering a Person (elevated to a Class A misdemeanor).
- At trial, the defense sought to admit a videotaped pre-trial statement of Deputy Walker; the court excluded the unredacted tape after finding impeachment value had already been achieved through cross-examination and citing judicial economy.
- A jury convicted Williams; he was sentenced to 365 days with 364 suspended to probation. The written order imposed various probation and alcohol/drug fees, despite an oral finding of indigency waiving fines and costs.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| 1. Admission of videotaped pre-trial statement | Trial court acted within discretion to exclude evidence that was cumulative and not necessary after impeachment on cross-exam | Tape was relevant impeachment evidence and would have shown officer confusion about sobriety testing and the failure to obtain blood test warrant | Trial court did not abuse discretion; exclusion harmless because impeachment achieved through testimony |
| 2. Sufficiency of evidence for "endangering a person" elevation | Evidence of erratic, unsafe driving (speeding, lane crossing, running red light) supports endangerment element | Argued insufficiency as elevation requires more than intoxication alone | Conviction affirmed; reasonable factfinder could find endangerment from observed unsafe driving |
| 3. Imposition of probation and program fees after indigency finding | Court properly imposed statutory probation and program fees and defendant invited sliding-scale arrangement | Indigency finding should relieve monetary obligations; probation department may not set sliding-scale fees | No sentencing error; written order consistent with defendant's requested probation and sliding-scale; invited error bar applies |
| 4. Request to remand to remove monetary obligations | State: written order reflects court-ordered fees within statutory authority | Williams: requested remand to correct written order to reflect no monetary obligation | Denied; court found no inconsistency between oral waiver of fines/costs and written fee order and declined relief |
Key Cases Cited
- Griffith v. State, 31 N.E.3d 965 (2015) (trial court evidence rulings reviewed for abuse of discretion)
- Hastings v. State, 58 N.E.3d 919 (2016) (definition of appellate abuse-of-discretion review for evidentiary rulings)
- Outlaw v. State, 929 N.E.2d 196 (2010) (intoxication alone does not automatically satisfy endangerment element)
- Staten v. State, 946 N.E.2d 80 (2011) (unsafe driving practices while intoxicated can support endangerment)
- Love v. State, 73 N.E.3d 693 (2017) (standard for sufficiency review—view evidence and reasonable inferences supporting verdict)
- Burnett v. State, 74 N.E.3d 1221 (2017) (trial court—not probation department—has authority to impose misdemeanor probation fees)
- Kelnhofer v. State, 857 N.E.2d 1022 (2006) (doctrine that a party cannot invite error and later seek relief on that ground)