Salvador A. Jones v. State of Indiana
24A-CR-01102
Ind. Ct. App.Apr 14, 2025Background
- Salvador A. Jones was convicted of Level 5 felony robbery for robbing a New Albany, Indiana bank as part of a month-long spree involving several Louisville, Kentucky banks.
- Jones was apprehended after police tracked a getaway vehicle linked to both the Indiana and Kentucky robberies, registered to his wife, and subsequently tracked Jones to Tennessee where he was arrested while wearing a wig.
- During his incarceration on related federal charges, Jones attempted to invoke his right to speedy trial under the Interstate Agreement on Detainers (IAD), but did not follow the strict statutory procedure to do so.
- The trial court denied Jones's motion to dismiss for violating the IAD’s 180-day trial requirement, rejected his claims for pre-hearing right to counsel, admitted various evidence over his objections, and sentenced him to the maximum six years.
- Jones appealed on procedural, constitutional, evidentiary, and sentencing grounds.
Issues
| Issue | Jones's Argument | State's Argument | Held |
|---|---|---|---|
| Right to 180-day trial under IAD | Jones claimed he timely invoked IAD for speedy trial | State: Jones did not strictly comply with IAD procedure | Jones failed to strictly comply; no IAD violation |
| Right to counsel pre-Indiana custody | Right attached when information was filed or via request to trial court | Right attaches at initial appearance before Indiana judicial officer or Indiana custody | Right did not attach before Indiana custody or hearing |
| Admission of self-authenticating affidavits (evidence) | Affidavits not timely and improperly admitted | Properly authenticated and noticed; no fundamental error | No fundamental error; admissible |
| Admission of Kentucky robbery evidence | Prior bad acts not probative of identity (not a signature crime) | Relevant for identity, close in time/place/circumstance | Properly admitted under Rules 403 & 404(b) |
| Six-year sentence appropriateness | Sentence excessive given the offense/character | Sentence warranted due to history and parole status | Sentence not inappropriate |
Key Cases Cited
- State v. Robinson, 863 N.E.2d 894 (Ind. Ct. App. 2007) (strict compliance required under IAD, 180-day clock triggered by formal detainer)
- State v. Greenwood, 665 N.E.2d 579 (Ind. 1996) (IAD procedures not mere technicalities; defendant must comply strictly)
- Hall v. State, 177 N.E.3d 1183 (Ind. 2021) (standard of review for evidentiary decisions)
- Fairbanks v. State, 119 N.E.3d 564 (Ind. 2019) (use of prior bad acts under Rule 404(b); relevance and prejudice standards)
- McCallister v. State, 91 N.E.3d 554 (Ind. 2018) (silent-witness doctrine requirements for admitting surveillance evidence)
- Stephenson v. State, 29 N.E.3d 111 (Ind. 2015) (Appellate Rule 7(B) sentence review framework)