Trenton Teague v. State of Indiana
978 N.E.2d 1183
| Ind. Ct. App. | 2012Background
- Teague was convicted by a Wayne Circuit Court jury of Class A felony burglary and Class C felony battery, receiving a combined sentence of 38 years for burglary plus 6 years for battery with 4 suspended.
- The offenses involved a September 25, 2010 assault on Chelsea Saylor and a prior/ongoing pattern of domestic violence; a separate October 4–5, 2010 home invasion against Staci Behnen left Behnen heavily injured.
- A 911 recording captured Bishop relaying statements by Saylor about the incident; the recording was admitted at trial.
- Teague was apprehended in Florida in 2011 and extradited to Indiana for trial, which occurred in December 2011; Counts II, III, IV, and V were merged into Count I (burglary), with a consecutive six-year sentence on Count VI (battery) and four years suspended.
- On appeal, Teague challenges the admissibility of the 911 recording and asserts the 40-year executed sentence is inappropriate; the court affirms both the evidentiary ruling and the sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of the 911 recording | Teague (Teague) argues Bishop’s statements to the 911 operator were not an excited utterance and thus inadmissible | The State contends Bishop’s responses relaying Saylor’s statements were excited utterances under Rule 803(2) and reliable | Admitted as excited utterances; harmless error |
| Appropriateness of the sentence | Teague argues the aggregate sentence is inappropriate given the offense and his character | The State contends the trial court rightly weighed aggravating factors; the sentence falls within statutory ranges | Forty-year aggregate executed sentence appropriate |
Key Cases Cited
- Lehman v. State, 926 N.E.2d 35 (Ind. Ct. App. 2010) (evidentiary ruling abuse of discretion standard)
- Iqbal v. State, 805 N.E.2d 401 (Ind. Ct. App. 2004) (hearsay exception logic and standard of review)
- Palacios v. State, 926 N.E.2d 1026 (Ind. Ct. App. 2010) (Rule 805 requirement for multiple hearsay exceptions)
- Lawrence v. State, 959 N.E.2d 385 (Ind. Ct. App. 2012) (excited utterance elements and reliability factors)
- Yamobi v. State, 672 N.E.2d 1344 (Ind. 1996) (excited utterance may be in response to questions; spontaneity shown by context)
- Noojin v. State, 730 N.E.2d 672 (Ind. 2000) (personal knowledge requirement for excited utterance; addressing relayed statements)
- Boatner v. State, 934 N.E.2d 184 (Ind. Ct. App. 2010) (harmless error review for evidentiary rulings)
- Turner v. State, 953 N.E.2d 1039 (Ind. 2011) (harmless error—substantial independent evidence)
- Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (sentencing factors and deference to trial court)
- Trainor v. State, 950 N.E.2d 352 (Ind. Ct. App. 2011) (principles for appellate review of sentences)
- Heinzman v. State, 970 N.E.2d 214 (Ind. Ct. App. 2012) (aggregate sentence considerations)
- Smith v. State, 889 N.E.2d 261 (Ind. 2008) (considerations of prior offenses and current conduct)
- Childress v. State, 848 N.E.2d 1073 (Ind. 2006) (factors in evaluating sentence appropriateness)