Maurice Knight v. State of Indiana
2015 Ind. App. LEXIS 589
| Ind. Ct. App. | 2015Background
- Knight and Deanna were in a romantic relationship; Deanna obtained a protective order on April 25, 2014. Deputy Sprunger served it; Knight refused to accept/sign and was transported off the property.
- On May 18, 2014 Deanna received text messages on her iPhone from a contact labeled “Maurice” stating he was coming; she reported feeling threatened.
- On May 20, 2014 a call to Deanna’s phone showed “Maurice”; Deputy Sprunger answered and heard a male voice she recognized as Knight threaten Deanna.
- Knight was arrested May 22 for violating the protective order. While jailed, recorded calls from the same male voice (identified as “Maurice” on the tapes) contained multiple explicit threats to Deanna on June 10, 24, 29, and 30.
- The State charged numerous counts; after bench trial the court convicted Knight of two counts of Class D felony invasion of privacy (May 18 & May 20 incidents) and four counts of Class D felony intimidation (the four jail calls) and sentenced him to concurrent three-year terms served consecutively for an aggregate six-year term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for invasion of privacy (May 18 texts) | Evidence showed texts came from contact labeled “Maurice” on May 18; court may infer Knight sent them. | Identity uncertain; messages lacked explicit dates and could be from another number labeled “Maurice.” | Conviction affirmed: trier of fact reasonably concluded texts came from Knight. |
| Sufficiency of evidence for invasion of privacy (May 20 call) | Call displayed as from “Maurice”; Deputy Sprunger recognized Knight’s voice and heard him refer to having been “shamed” — consistent with prior statements. | Questioned reliability of voice ID after brief exposure and timing. | Conviction affirmed: voice ID and content supported finding Knight placed the call. |
| Sufficiency of evidence for intimidation (jail calls) | Recorded jail calls identified speaker as “Maurice”; witnesses (victim’s mother and deputy) recognized Knight’s voice and tapes contained threats. | Jail logs suggested another inmate might have placed calls; identity thus disputed. | Convictions affirmed: voice identifications and tapes supported that Knight made the threatening calls. |
| Applicability of Neill v. Biggers (challenging voice IDs) | State relied on totality of circumstances for identification; admissibility not challenged. | Cited Neill to cast doubt on reliability of identification. | Court rejected Neill-based attack: Neill concerned suggestive visual IDs; here totality supported reliable voice identifications. |
Key Cases Cited
- Neill v. Biggers, 409 U.S. 188 (U.S. 1972) (discusses reliability factors for in-court identification under totality of circumstances)