Roy Bell v. State of Indiana, 31 N.E.3d 495

On Nov. 22, 2011, 81-year-old Wilma Upsall was found bound and shot to death in the home she shared with Timothy and Deborah Richardson; guns and jewelry were missing from the house.
Surveillance linked three men (William Scroggs, Jason Miller, Roy Bell) to an El Camino-type vehicle; a high-speed chase ended in a crash where police recovered jewelry, an extension cord, and firearms identified by the homeowner.
A homemade black mask recovered along the chase route contained a DNA mixture that did not exclude Bell as a contributor; Michelle Rzepczynski told police Bell confessed to her and said his mask fell off and he fired two clips.
Bell was arrested, waived Miranda rights, and gave a recorded statement admitting entry and tying up a woman but denying he killed her; he later stipulated to admission of his statement and Rzepczynski’s transcription at a bench trial.
Bell was convicted of murder (among other offenses) and sentenced to life without parole; he appealed solely arguing insufficient evidence to sustain the murder conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bell)	Held
Sufficiency of evidence for murder conviction	Evidence (DNA on mask, Rzepczynski’s statement, Bell’s admissions about entry/taking guns) supports verdict	No physical evidence tying Bell to the killing; his and Rzepczynski’s statements are unreliable/hearsay	Affirmed: admitted statements and DNA evidence permitted a reasonable fact-finder to convict
Voluntariness and admissibility of Bell’s confession	Bell waived Miranda; recording and waiver show voluntariness; no coercive police conduct	Bell was sleep-deprived, scared, without counsel, and threatened with death/LWOP, rendering statement unreliable	Waiver valid; explanation of penalties is not a coercive threat; confession admissible
Reliability/admissibility of Rzepczynski’s statement	Statement was stipulated and admissible; trier of fact entitled to weigh credibility	She was a drug user, awakened early, had motive to lie, and her account conflicted with physical evidence	Stipulation waived evidentiary challenge; credibility is for fact-finder, not appellate reweighing
Sufficiency based on physical evidence (DNA)	DNA on mask linking Bell as possible contributor corroborates confession that mask fell off	DNA was a mixture and not direct proof of participation in killing	DNA evidence—combined with admissions and other evidence—was probative and sufficient

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warning requirement for custodial interrogation)
Colorado v. Connelly, 479 U.S. 157 (1986) (voluntariness requires coercive police activity; defendant’s mental state alone insufficient)
Ferrell v. State, 746 N.E.2d 48 (Ind. 2001) (standard for sufficiency review; do not reweigh evidence)
Lowery v. State, 547 N.E.2d 1046 (Ind. 1989) (principle that one who aids or induces another may be responsible for the offense)
Marshall v. State, 621 N.E.2d 308 (Ind. 1993) (testimony believed by trier of fact is sufficient to uphold verdict)
Wright v. State, 828 N.E.2d 904 (Ind. 2005) (party may not complain of error it invited by stipulation)
Morgan v. State, 587 N.E.2d 680 (Ind. 1992) (explaining that informing defendant of potential penalties is not a coercive inducement)
Madison v. State, 534 N.E.2d 702 (Ind. 1989) (similar principle that explaining possible penalties does not render confession involuntary)