Michael Jurell Jones v. State of Indiana (mem. dec.), 71A03-1604-CR-713

Background

On July 11, 2015, after an altercation outside a bar, Michael Jones retrieved a handgun from his car and fired multiple shots, killing Eddy Hill. Hill was unarmed; some wounds were consistent with shots fired after Hill was on the ground. No gun was recovered at the scene; Jones later discarded the weapon while driving to Georgia, then returned and surrendered.
The State charged Jones with murder; Jones pleaded self-defense at trial. The jury convicted him and the trial court sentenced him to 55 years.
At booking, Deputy Matt Sterling asked routine medical questions; Jones volunteered that he blacked out "from extreme anger, like the other night, and here I am." The court admitted that testimony over Jones’s Miranda-based objection, citing routine booking-question doctrine.
The prosecutor made several contested statements: during voir dire that the presumption of innocence is "a safeguard for the innocent, but not a shield for the guilty," during closing that mere verbal threats don’t justify deadly force, and a rebuttal remark distinguishing "beyond a reasonable doubt" from "beyond all reasonable doubt." Jones did not object at trial.
The defense proffered a demonstrative slide (a bar graph) to illustrate "beyond a reasonable doubt;" the court sustained the State’s objection and excluded the slide as misleading.

Issues

Issue	State's Argument	Jones's Argument	Held
Whether admission of Sterling’s booking testimony violated Miranda and was an abuse of discretion	Booking medical questions are routine, aimed at inmate safety and housing; the follow-up and Jones’s volunteered statement were not interrogation	The follow-up went beyond routine booking and elicited incriminating, uncounseled statements; Miranda violation	Admission was proper: routine booking exception applies; any excess was volunteered and admissible
Whether evidence was sufficient to disprove self-defense	Evidence (multiple shots, wounds consistent with being shot while down, Hill unarmed, Jones’s statements about anger) rebutted at least one element of self-defense	Jones reasonably feared for his life when Hill approached and threatened to shoot; self-defense justified	Sufficient evidence to negate self-defense; conviction affirmed
Whether prosecutor’s remarks constituted prosecutorial misconduct/fundamental error	Remarks about verbal threats and reasonable doubt were legally permissible; the voir dire comment was improper but not fundamentally prejudicial given instructions	Remarks diluted presumption of innocence and the burden of proof, denying fair trial	Only the voir dire comment was improper; not fundamental error because court instructions cured potential prejudice
Whether court erred excluding defense demonstrative slide on reasonable doubt	Slide was misleading (quantifies an imprecise standard); accurate jury instructions and other means existed to convey burden	Excluding the slide prevented complete defense and violated due process	Exclusion was within the trial court’s discretion; no abuse of discretion

Key Cases Cited

Loving v. State, 647 N.E.2d 1123 (Ind. 1995) (routine booking questions may fall outside Miranda interrogation requirement)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings about right to remain silent and counsel)
Rhode Island v. Innis, 446 U.S. 291 (U.S. 1980) (Miranda’s definition of "interrogation" includes words or actions reasonably likely to elicit incriminating responses)
Wilson v. State, 765 N.E.2d 1265 (Ind. 2002) (standard for reviewing admission of evidence and legal framework for self-defense burden)
Timmons v. State, 500 N.E.2d 1212 (Ind. 1986) (presumption of innocence is a core component of a fair trial; courts must guard against its dilution)
Cooper v. State, 854 N.E.2d 831 (Ind. 2006) (framework for analyzing prosecutorial misconduct and the narrowness of fundamental-error review)