Pattison v. State
958 N.E.2d 11
Ind. Ct. App.2011Background
- Pattison was convicted of murder in Indiana.
- Investigators found Pattison’s home surveillance system and later obtained a warrant to seize it and its recordings.
- Video from July 2, 2009 showed Pattison at and around his home earlier than he claimed after Lisa’s death.
- During trial, the surveillance equipment and video were admitted into evidence, and a large weightlifting machine was kept in the courtroom for jurors to inspect during deliberations.
- Jurors entered the courtroom during deliberations to examine the machine, allegedly conducting experiments.
- Pattison challenged the admissibility of the surveillance evidence and later sought a mistrial; the trial court denied relief and Pattison appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of surveillance evidence | Pattison: Fourth Amendment and Article 1, Section 11 were violated. | Pattison: warrant lacked probable cause due to stale/unreliable information. | Affirmed admission; probable cause supported warrant. |
| Jurors’ examination of the weightlifting machine | Pattison: jurors’ inspection during deliberations was improper and prejudicial. | Pattison: the examination was allowed and not improper. | Jurors’ examination was permissible; not an improper experiment. |
| Denial of request to question jurors about experiments | Pattison: should have questioned jurors to address potential extraneous information. | No improper extraneous information; no need for hearings. | Trial court did not abuse discretion; no mistrial required. |
| Sufficiency of the evidence | State presented sufficient evidence to prove Pattison killed Lisa beyond a reasonable doubt. | Evidence does not preclude reasonable doubt; reweighing disallowed. | Evidence sufficient; murder conviction affirmed. |
Key Cases Cited
- McHenry v. State, 820 N.E.2d 124 (Ind.2005) (abuse-of-discretion review for evidentiary rulings)
- Jackson v. State, 908 N.E.2d 1140 (Ind.2009) (probable cause and search-warrant standards)
- Gates v. Illinois, 462 U.S. 213 (U.S.1983) (probable cause based on totality of circumstances)
- Foy v. State, 862 N.E.2d 1219 (Ind.2007) (corroboration of hearsay and probable cause)
- Mehring v. State, 884 N.E.2d 371 (Ind.Ct.App.2008) (doubtful cases resolved in favor of upholding warrants)
- Bradford v. State, 675 N.E.2d 296 (Ind.1996) (jury experiments and admissibility of evidence during deliberations)
- Hope v. State, 903 N.E.2d 988 (Ind.2010) (proper denial of juror-questioning in verdict validity)
- Hape v. State, 903 N.E.2d 977 (Ind.Ct.App.2009) (juror testimony and limited exceptions under Rule 606(B))
- Kennedy v. State, 578 N.E.2d 633 (Ind.1991) (admission of evidence and juror deliberations context)