Nathaniel Baker v. State of Indiana
997 N.E.2d 67
Ind. Ct. App.2013Background
- In the early hours of December 5, 2011, Baker, J.L., and Zellers stole approximately 45 gallons of gasoline from Stephan's farm in Huntington County; Stephan did not authorize the theft.
- J.L. told police he and Baker had stolen gasoline on prior occasions; Zellers admitted participation and led detectives to the theft site.
- Baker was charged with one count of Class D felony theft on December 15, 2011; trial occurred September 23, 2012, with an alibi defense from Baker's fiancée Draper.
- Draper testified that Baker was with her from around 1:30 a.m. to about 4:00 a.m., reinforcing his alibi; the State challenged this credibility.
- During trial, the State admitted evidence of Baker's prior bad acts over Baker's objection; the jury found Baker guilty as charged and the court imposed 1.5 years, with one year suspended.
- On appeal, Baker contends the trial court abused its discretion by admitting 404(b) evidence; the court held the admission was error but harmless in light of independent testimonial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Baker's prior bad acts were admissible under Rule 404(b). | State argues evidence shows knowledge, identity, and intent to refute alibi. | Baker asserts evidence is not admissible for knowledge, identity, or intent; admissibility was improper. | Admission was error; not admissible under 404(b). |
Key Cases Cited
- Whitehair v. State, 654 N.E.2d 296 (Ind. Ct. App. 1995) (knowledge exception requires knowledge at issue)
- Thompson v. State, 690 N.E.2d 224 (Ind. 1997) (identity exception requires striking similarity of prior acts)
- Wickizer v. State, 626 N.E.2d 795 (Ind. 1993) (intent exception requires defendant place intent at issue)
- Goldsberry v. State, 821 N.E.2d 447 (Ind. Ct. App. 2005) (balance probative value against prejudicial effect)
- Meadows v. State, 785 N.E.2d 1112 (Ind. Ct. App. 2003) (harmless-error standard for improper 404(b) admission)
- Ware v. State, 816 N.E.2d 1167 (Ind. Ct. App. 2004) (abuse-of-discretion review for evidentiary rulings)