Todd A. Stigleman v. State of Indiana (mem. dec.)
89A01-1608-CR-1783
| Ind. Ct. App. | Apr 27, 2017Background
- Todd Stigleman forcibly controlled and harassed his estranged wife, Kelli, across multiple incidents in March–April 2014 (four kidnappings; some involved a knife and one involved forced intercourse); he also involved their son in some events.
- Police reports, family testimony, surveillance, and physical evidence corroborated Kelli’s account; Stigleman was arrested after the April 24 incident.
- State charged 14 counts: four Class A kidnapping counts, eight Class C criminal confinement counts, and two Class C stalking counts; an habitual-offender enhancement was alleged.
- Trial court denied Stigleman’s motion to sever; the jury convicted on all counts; the court later vacated the criminal-confinement convictions and sentenced Stigleman to an aggregate 76-year term (including a 30-year habitual-offender enhancement).
- On appeal Stigleman challenged: (1) denial of severance, (2) admission of prior-bad-acts evidence under Evid. R. 404(b), and (3) the appropriateness of his sentence under Appellate Rule 7(B).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Stigleman) | Held |
|---|---|---|---|
| Denial of severance of joined counts | Joinder proper because the incidents were connected by victim, method, and motive (so subsection 35-34-1-9(a)(2) applies) | Counts were joined only for similar character; Stigleman was entitled to severance as a matter of right | Affirmed: crimes formed a pattern (same victim, modus operandi, motive); no right to severance; alternative severance factors also weighed against severance |
| Admission of other-bad-acts evidence under Evid. R. 404(b) | Evidence (tire tampering, attempted framing with drugs/gun, letters asking for false testimony) showed consciousness of guilt, intent, motive and was admissible; limiting instructions given | Such evidence was highly prejudicial and not probative of issues at trial | Affirmed: evidence admissible for non-propensity purposes (guilty knowledge/intent); any error harmless given strong independent evidence and limiting instructions |
| Inappropriateness of aggregate 76-year sentence | Sentence justified by severity, repeated kidnappings, sexual assault, use of child, attempts to subvert justice, and criminal history including prior stalking; habitual enhancement required under prior code | Sentence excessive and should be revised under App. R. 7(B) | Affirmed: sentence not inappropriate in light of nature of offenses and offender’s character; habitual-offender enhancement applied under saving clause |
Key Cases Cited
- Pierce v. State, 29 N.E.3d 1258 (Ind. 2015) (distinguishes joinder under same-character vs. connected-acts tests)
- Craig v. State, 730 N.E.2d 1262 (Ind. 2000) (modus operandi and motive can link offenses to deny severance)
- Wilkerson v. State, 728 N.E.2d 239 (Ind. Ct. App. 2000) (severance required when similar offenses are factually distinct)
- Maymon v. State, 870 N.E.2d 523 (Ind. Ct. App. 2007) (severance where burglaries were not part of a connected series)
- Matthews v. State, 866 N.E.2d 821 (Ind. Ct. App. 2007) (threats to witnesses admissible as evidence of guilty knowledge)
- Bowman v. State, 51 N.E.3d 1174 (Ind. 2016) (letters soliciting false testimony admissible under 404(b) to show guilty mind)
- Hicks v. State, 690 N.E.2d 215 (Ind. 1997) (framework for assessing 404(b) evidence: relevance to non-propensity purpose and Rule 403 balancing)
- VanPatten v. State, 986 N.E.2d 255 (Ind. 2013) (harmless-error standard for admission of evidence)
- Hoglund v. State, 962 N.E.2d 1230 (Ind. 2012) (substantial independent evidence can render erroneous admission harmless)