Steven Lindsey v. State of Indiana (mem. dec.)
64A04-1703-CR-482
| Ind. Ct. App. | Oct 25, 2017Background
- Victim Melinda was shot in the head in her home in January 2015; her husband Steven Lindsey discovered her and called 911. The gun belonged to Melinda and was found in the bedroom.
- Circumstantial facts prompting scrutiny: financial stress, Lindsey as sole life‑insurance beneficiary, cremation of the body against family wishes, attempts to sell jewelry, and euthanasia of victim’s dogs shortly after death.
- Investigative facts: zip ties found, a distinctive boot print on the porch later matched to boots Lindsey wore to the station, and small blood stains on the wall near the headboard that DNA showed were Lindsey’s. Lindsey claimed an unknown intruder; several third‑party suspects were investigated and eliminated or implicated by hearsay/confession allegations.
- Procedural history: First trial (Sept. 2015) ended in mistrial after new evidence surfaced midtrial; second trial (Nov. 2015) ended in mistrial (hung jury); third trial (Feb. 2016) produced a guilty verdict for murder and a 55‑year sentence. Lindsey appealed raising seven issues.
- Trial rulings at issue included denial of midtrial continuance, limited juror inquiry, admission of Lindsey’s blood evidence, exclusion of police‑interview videos, denial of Lindsey reading his prior testimony, propriety of the first mistrial (double jeopardy), and admission of veterinary records showing euthanasia.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Lindsey) | Held |
|---|---|---|---|
| Denial of midtrial continuance after discovery that a boot matched a porch print | New match promptly disclosed; weight for jury; no deliberateness by State | Needed more time to investigate match; prejudice from surprise midtrial disclosure | Trial court did not abuse discretion; defendant failed to show specific need for additional time and evidence was not central to guilt |
| Juror inquiry regarding Juror 7’s travel plans | Court properly asked juror and offered dismissal; juror chose to stay | Court should have probed further for potential bias from disrupted travel plans | No fundamental error; court reasonably concluded low risk of bias and defendant waived further questioning |
| Admission of Lindsey’s blood on bedroom wall | Evidence relevant to eliminate third‑party theories and describe crime scene; timing/transfer issues for jury | Blood unrelated to murder and highly prejudicial; could only invite speculation | Admission within trial court’s discretion; relevance and probative value outweighed speculation—jury to resolve timing/how it got there |
| Exclusion of video recordings of police interviews about third‑party confession | Exclusion reasonable because videos lacked strong probative value and witnesses had testified; defendant could cross‑examine officers | Videos non‑hearsay for purpose of showing police failed to investigate and thus relevant to defense | No abuse of discretion; videos not shown to have sufficient probative value and exclusion did not deny constitutional right to present defense |
| Denial of defendant reading his prior trial testimony when State read it | Court may control the manner of reading to avoid embellishment; reading by neutral detective proper | Defendant’s demeanor while reading was essential to credibility; only he could provide proper presentation | Court’s decision was a valid exercise of trial management; defendant testified at trial so demeanor available; no prejudice shown |
| First‑trial mistrial (double jeopardy) | Mistrial declared to protect defendant’s rights given large new discovery; parties (including Lindsey) tacitly consented; retrial permitted | Lindsey did not consent; mistrial not manifest necessity; retrial barred by double jeopardy | Retrial permissible: Lindsey tacitly consented (failed to object) and, even absent consent, mistrial was justified by manifest necessity |
| Admission of veterinary records showing Lindsey consented to euthanize dogs | Records relevant to (1) show dog’s aggressive nature undermining intruder theory and (2) demonstrate behavior inconsistent with grieving widower | Records irrelevant and unfairly prejudicial (appeal to jurors’ emotions) | Admission not an abuse of discretion; records relevant and probative, not unduly prejudicial |
Key Cases Cited
- Clark v. State, 539 N.E.2d 9 (Ind. Ct. App.) (standard for showing additional time would have aided defense)
- Johnson v. State, 384 N.E.2d 1035 (Ind. Ct. App.) (midtrial identification of expert required continuance)
- Caruthers v. State, 926 N.E.2d 1016 (Ind.) (trial court need only investigate juror bias when substantial likelihood of prejudice exists)
- Crane v. Kentucky, 476 U.S. 683 (1986) (defendant’s right to present a complete defense is not absolute)
- Taylor v. Illinois, 484 U.S. 400 (1988) (limits on defendant’s right to introduce evidence that is inadmissible under rules)
- Oregon v. Kennedy, 456 U.S. 667 (1982) (double jeopardy principles when mistrial declared)
- Arizona v. Washington, 434 U.S. 497 (1978) (retrial after mistrial allowed when manifest necessity)
- Brock v. State, 955 N.E.2d 195 (Ind.) (tacit consent to mistrial; standards for retrial)