Timothy J. Jimerson v. State of Indiana
2016 Ind. App. LEXIS 209
| Ind. Ct. App. | 2016Background
- In 1992 Toni Spicer was beaten and strangled; a hair recovered from her body later produced a DNA match to Timothy Jimerson after cold-case testing.
- In 2012 Indiana detectives interviewed Jimerson in Mississippi; he initially denied but ultimately confessed on videotape, then was charged with murder.
- At trial the jury convicted Jimerson of voluntary manslaughter (lesser included offense) and he received a 45-year sentence.
- Pretrial Jimerson moved to suppress his statement as psychologically coerced; the motion was denied. He then sought to present Dr. Richard Leo as an expert on false confessions.
- The trial court allowed Dr. Leo to testify about the general phenomena of false confessions and problematic interrogation practices but barred him from testifying that specific techniques used in Jimerson’s interrogation rendered the confession false or coerced.
- Jimerson appealed, arguing the court abused its discretion by restricting the expert’s ability to link interrogation techniques to the specifics of his statement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by limiting expert testimony on false confessions | State: Limitations were appropriate to prevent expert opinion on truth/falsity and to preserve the jury's province | Jimerson: Expert should be allowed to identify specific techniques used in his interrogation and opine they increased the risk of a false confession | Court: No abuse of discretion — expert could describe general phenomena and tactics; applying those concepts to the record was for the jury |
Key Cases Cited
- Callis v. State, 684 N.E.2d 233 (Ind. Ct. App. 1997) (permits expert testimony on the phenomenon of coerced confessions but excludes expert opinions on truth/falsity of a particular interrogation)
- Miller v. State, 770 N.E.2d 763 (Ind. 2002) (holds experts may explain psychology of false confessions and police techniques, and wholesale exclusion of such testimony can deprive defendant of a defense)
- Shelby v. State, 986 N.E.2d 345 (Ind. Ct. App. 2013) (permits extended expert testimony on coercive tactics but limits testimony that would directly opine a particular confession was false or coerced)