Reginald Harris v. State of Indiana
2017 Ind. LEXIS 476
Ind.2017Background
- Early one November morning Reginald Harris and Summer Snow fought; Harris sat in Snow’s car after being kicked out and refused to exit when Officer Terry Peck arrived.
- A scuffle occurred in which Harris pulled Peck into the car and struck him; Peck handcuffed Harris and placed him in a patrol car.
- While arresting Snow, a handgun she was carrying fell, struck Peck’s knee/boot, and landed on the ground. Neither defendant was charged with a gun offense.
- The State tried Harris and Snow jointly; the same attorney represented both, and the trial court admitted Snow’s gun into evidence over objection.
- Harris was convicted of Level 5 felony battery on a public safety official and Level 6 felony resisting law enforcement; he appealed, arguing the gun’s admission was improper and prejudicial.
- The Supreme Court granted transfer, held the gun’s admission was within the trial court’s discretion, and concluded Harris waived his fair-trial prejudice claim (no separate trial requested, no limiting instruction sought), affirming his convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Snow’s gun under evidentiary rules | State: gun is admissible and trial court acted within discretion | Harris: gun irrelevant to his conduct and should be excluded | Court: admission was within trial court’s discretion (consistent with companion Snow opinion) |
| Relevance of gun to Harris’s charges | State: evidence properly admitted for case context | Harris: gun not relevant because he was handcuffed before gun appeared | Court: gun indeed not relevant to Harris’s crimes, but admissibility was not erroneous given discretion exercised |
| Prejudice / denial of fair trial from gun’s admission | State: no unfair prejudice warranting reversal | Harris: admission prejudiced jury against him, denying fair trial | Court: claim waived—Harris failed to request separate trial or limiting instruction and raised claim too late; no fundamental error shown |
| Trial court duty to give limiting instruction sua sponte | State: no affirmative duty without request | Harris: court should have sua sponte limited jury’s consideration of gun | Court: no duty to give admonishment sua sponte; jury was instructed to consider each defendant separately; no fundamental error |
Key Cases Cited
- Zanders v. State, 73 N.E.3d 178 (Ind. 2017) (standard of review for evidentiary rulings is abuse of discretion)
- Gibson v. State, 51 N.E.3d 204 (Ind. 2016) (explaining fundamental-error standard and heavy burden on appellant)
- Humphrey v. State, 73 N.E.3d 677 (Ind. 2017) (issues raised first at oral argument are waived)
- Fredrick v. State, 755 N.E.2d 1078 (Ind. 2001) (failure to move for separate trial waives right to separate consideration)
- Sanchez v. State, 675 N.E.2d 306 (Ind. 1996) (claim waived when no limiting instruction tendered or requested)
- Sims v. Pappas, 73 N.E.3d 700 (Ind. 2017) (party seeking limiting instruction has duty to request it)
- Griffith v. State, 59 N.E.3d 947 (Ind. 2016) (describes the daunting standard for prevailing under fundamental-error review)
- Shoun v. State, 67 N.E.3d 635 (Ind. 2017) (elements of fundamental-error analysis)
- Knapp v. State, 9 N.E.3d 1274 (Ind. 2014) (prejudice standard under fundamental-error doctrine)
- Washington v. State, 808 N.E.2d 617 (Ind. 2004) (trial court has no affirmative duty to give admonishment absent a request)
- Smith v. State, 721 N.E.2d 213 (Ind. 1999) (same principle regarding court’s duty to give limiting instructions)