Michael Miller v. State of Indiana
72 N.E.3d 502
| Ind. Ct. App. | 2017Background
- On August 10, 2014 Michael Miller (then 24) walked up to Jeremy Kohn on a porch, cut Kohn’s throat with a 3–4 inch pocketknife; wound required >40 stitches but did not sever major vessels or trachea.
- Miller was arrested days later; during a police interview he admitted the act, denied being psychotic, and spoke calmly; he said he didn’t care whether Kohn lived.
- Miller had a lengthy history of mental-health treatment and was later diagnosed with paranoid schizophrenia; defense filed notice of mental-disease defense and multiple experts (court-appointed and defense) examined him.
- Trial court found Miller incompetent, committed him to a state hospital; he was later certified competent and returned to jail; Miller filed a speedy-trial motion after hospital release.
- State sought a continuance so its retained psychiatrist (Dr. Crane) could review records and evaluate Miller; trial was continued beyond the 70-day Rule 4(B) period under Rule 4(D); bench trial later occurred in January 2016.
- The court rejected Miller’s insanity defense (though two experts testified he met the statutory insanity standard and one said he appreciated wrongfulness but had irresistible impulse), convicted him guilty but mentally ill of Level 1 attempted murder and remanded for sentencing; appellate court reversed and remanded for new trial due to mens rea error.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Miller) | Held |
|---|---|---|---|
| 1. Whether continuance violated Criminal Rule 4(B) speedy-trial right | Continuance was justified under Rule 4(D) because Dr. Crane needed time to review records and evaluate defendant | Continuance put trial beyond 70-day limit and violated speedy-trial rights; he objected when continuance granted | Court held no Rule 4(B) violation: trial court did not abuse discretion in granting continuance under Rule 4(D) given complexity and State’s efforts |
| 2. Whether trial court properly rejected insanity defense | Demeanor evidence and one expert’s opinion that Miller appreciated wrongfulness supported rejection | Miller argued overwhelming expert testimony showed he was legally insane at the time | Court held rejection of insanity defense was supported: conflicting expert testimony plus probative demeanor evidence justified the finding |
| 3. Whether attempted-murder conviction used correct mens rea standard | State relied on charging language and trial-court findings referencing knowing/intentional conduct | Miller argued attempted murder requires specific intent to kill, not merely knowing conduct; charging info and findings used incorrect "knowing" wording | Court held trial court applied incorrect "knowing" mens rea rather than specific intent to kill; reversed and remanded for new trial with corrected information |
| 4. Remedy for bench-trial mens rea error | State: bench judge presumed to know and apply correct law; remand unnecessary | Miller: error in charging language and findings undermines conviction; new trial required | Court concluded presumption rebutted; ordered reversal and remand for new trial after filing amended information |
Key Cases Cited
- Austin v. State, 997 N.E.2d 1027 (Ind. 2013) (Rule 4 purpose and standard guidance)
- Zickefoose v. State, 388 N.E.2d 507 (Ind. 1979) (attempt crime requires specific intent plus substantial step)
- Spradlin v. State, 569 N.E.2d 948 (Ind. 1991) (attempted murder requires proof of intent to kill; "knowing" mens rea insufficient)
- Patton v. State, 810 N.E.2d 690 (Ind. 2004) (charging information must allege specific intent for attempted murder; notice/plea implications)
- Galloway v. State, 938 N.E.2d 699 (Ind. 2010) (limits of demeanor evidence when defendant has severe psychosis)
- Rosales v. State, 23 N.E.3d 8 (Ind. 2015) (Spradlin error precedent and treatment as fundamental error)