Thomas L. Hale v. State of Indiana
2016 Ind. LEXIS 429
| Ind. | 2016Background
- Thomas Hale was charged with Class A Dealing in Methamphetamine in Huntington, Indiana.
- Hale, claiming indigence, was appointed counsel and moved for depositions of two State witnesses at public expense.
- The trial court denied Hale's motion the same day, without a hearing or findings.
- Casto and Fisher, the two witnesses, testified at Hale's trial; Hale did not object at that time.
- Hale appealed; the Court of Appeals affirmed, but a dissent would have granted relief based on Murphy v. State.
- This Court granted transfer and reversed Hale’s conviction, remanding for a new trial, and provided guidance on future rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of depositions at public expense was an abuse of discretion | Hale | State | Abuse of discretion; reversal |
| What standard governs trial courts’ handling of indigent deposition motions | Hale | State | Apply Dillard three-part test with Crawford refinement |
| Does Murphy control waiver analysis for deposition motions | Hale | State | Murphy governs; merits considered despite waiver concerns |
| What guidance should trial courts follow when denying indigent deposition requests | Hale | State | Require explicit findings addressing Dillard/Crawford factors |
Key Cases Cited
- Murphy v. State, 265 Ind. 116 (Ind. 1976) (denial of public-expense depositions is an abuse of discretion)
- Dillard v. State, 257 Ind. 282 (Ind. 1971) (three-part test for discovery in criminal cases)
- In re WTHR-TV, 693 N.E.2d 1 (Ind. 1998) (explains three-factor balancing framework and considerations)
- Crawford v. State, 948 N.E.2d 1165 (Ind. 2011) (reaffirms Dillard test and discovery administration)
- Robey v. State, 7 N.E.3d 371 (Ind. Ct. App. 2014) (waiver considerations in appellate review of trial rulings)
- O’Conner v. State, 272 Ind. 460 (Ind. 1980) (distinguishes surprise testimony circumstances from Murphy)
- Halliburton v. State, 1 N.E.3d 670 (Ind. 2013) (fundamental error doctrine relevance in waiver context)
- Mathews v. State, 849 N.E.2d 578 (Ind. 2006) (describes substantial harm standard for fundamental error)