Quanardel Wells v. State of Indiana, 2014 Ind. App. LEXIS 22

Between June and July 2009, Wells committed multiple assaults on four women (all described as prostitutes) in Indianapolis, involving coercion, threats with knives, forced oral and vaginal sex, theft, and strangulation; several victims identified Wells from photo arrays.
State charged Wells with multiple counts across four incidents: Class A and B felony criminal deviate conduct and rape, criminal confinement, strangulation, and related charges; several charges later dismissed by the State prior to trial.
Wells moved to sever the offenses before trial; the trial court denied the motion, which was the subject of an earlier interlocutory appeal that the appellate court affirmed and which was reinstated by the Indiana Supreme Court.
At trial (May 2013) the jury convicted Wells on eight counts; the trial court imposed consecutive sentences on key counts resulting in a 100-year aggregate sentence.
Wells appealed arguing (1) the trial court erred in denying his motion to sever the offenses and (2) his aggregate sentence was inappropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether joinder of offenses and denial of severance was improper	State: Offenses share common modus operandi and motive; joinder proper under § 35-34-1-9(a)(2) and severance not needed	Wells: Joinder was improper (severance required); at trial defense focused on consent not identity and evidence presentation increased prejudice	Denied. Prior interlocutory ruling established joinder was proper; law of the case applies and trial facts did not differ to warrant revisiting severance; no undue prejudice shown
Whether 100-year aggregate sentence is inappropriate	State: Sentences within statutory ranges and justified by nature of offenses and offender's record	Wells: Sentence inappropriate because victims were prostitutes and some encounters began consensually; sentence fueled by addiction mitigation	Affirmed. Sentence not inappropriate given gravity of coercive, violent sexual conduct and Wells’s extensive criminal history

Ben-Yisrayl v. State, 690 N.E.2d 1141 (Ind. 1997) (modus operandi and common motive support joinder under connected-acts prong)
Penley v. State, 506 N.E.2d 806 (Ind. 1987) (definition of modus operandi as distinctive pattern linking crimes)
Davidson v. State, 558 N.E.2d 1077 (Ind. 1990) (joinder upheld where multiple offenses furnished germane and relevant evidence to each other despite prejudice)
Cutter v. State, 725 N.E.2d 401 (Ind. 2000) (law of the case doctrine explained and applied to decline re-litigation of earlier appellate rulings)
Anglemyer v. State, 868 N.E.2d 482 (Ind. 2007) (standards for sentence review and role of advisory sentence in appellate review)