Steven N. Hyland v. State of Indiana (mem. dec.)
02A05-1605-CR-1166
| Ind. Ct. App. | Apr 4, 2017Background
- Around 2:15 a.m., officers responded to a hit-and-run where a pedestrian suffered serious head injuries; witnesses identified a maroon station wagon and indicated a person known as "Neal"/"Click Clack" was involved.
- Officer Lisa Woods spotted and followed the maroon station wagon driven by Hyland after a witness reported the vehicle passed the scene.
- Hyland drove into a residential area, made multiple turns (some without signaling), and Officer Woods activated emergency lights and then siren before catching up and arresting him at a stop sign.
- Hyland was charged with Level 6 felony resisting law enforcement for knowingly/intentionally using a vehicle to flee after an officer identified herself and ordered him to stop.
- Hyland moved to suppress evidence from Officer Woods’ dash cam, arguing the stop lacked reasonable suspicion; the trial court denied the motion. Hyland was convicted by a jury and appealed, challenging admission of the evidence and sufficiency of evidence to sustain the conviction.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hyland) | Held |
|---|---|---|---|
| Whether admission of evidence from the stop was lawful (motion to suppress) | Officer Woods had reasonable suspicion based on witness ID, erratic driving, speed, and traffic infractions to justify the stop and admissibility | Stop violated Fourth Amendment because officer lacked reasonable suspicion; evidence obtained should be suppressed | Court held stop was supported by reasonable suspicion under totality of circumstances; evidence properly admitted |
| Whether the State presented sufficient evidence for Level 6 felony resisting law enforcement | Evidence showed Woods identified herself by activating lights/siren and Hyland knowingly fled by continuing to drive and failing to stop, satisfying statute | Hyland lacked awareness Officer Woods intended to stop him until right before stopping; State failed to prove knowing/intended flight | Court held evidence was sufficient; reasonable juror could find Hyland knowingly fled after identification |
Key Cases Cited
- Gaddie v. State, 10 N.E.3d 1249 (Ind. 2014) (officer’s order to stop must rest on probable cause or reasonable suspicion)
- Lundquist v. State, 834 N.E.2d 1061 (Ind. Ct. App. 2005) (standards for reviewing admissibility/suppression rulings)
- Moore v. State, 669 N.E.2d 733 (Ind. 1996) (contemporaneous and specific objection required to preserve suppression claims)
- McKnight v. State, 612 N.E.2d 586 (Ind. Ct. App. 1993) (reasonable suspicion may arise from matching vehicle description, proximity to crime, speeding, and traffic infractions)
- Drane v. State, 867 N.E.2d 144 (Ind. 2007) (appellate courts do not reweigh evidence or assess witness credibility on sufficiency review)
- Woodward v. State, 770 N.E.2d 897 (Ind. Ct. App. 2002) (continuation of driving after officer activates lights/siren supports felony resisting charge)