Tyrice J. Halliburton v. State of Indiana
1 N.E.3d 670
| Ind. | 2013Background
- March 18, 2008, Sheena Kiska killed in Bristol, Indiana; Halliburton neighbor who helped unlock door with a bend screwdriver.
- Halliburton gave multiple statements; third interview contradicted earlier versions, including a claim of seeing another resident and hearing noises.
- State charged Halliburton with murder and sought life imprisonment without parole; later added habitual offender allegation.
- Trial featured numerous exhibits (photos, autopsy images, burglary evidence) and a witness who testified about DeFronzo’s statements.
- Jury found Halliburton guilty of murder; penalty phase led to life without parole; court sentenced accordingly.
- Halliburton appeals asserting evidentiary errors and a faulty limiting instruction; the Supreme Court affirms the trial court’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admission of specific photographs was proper | Halliburton | Halliburton | No abuse of discretion; photographs admissible for probative value |
| Whether DeFronzo’s mother’s testimony constituted improper vouching | Halliburton | Halliburton | No error, not fundamental; testimony did not bolster credibility improperly |
| Whether 404(b) burglary evidence was admissible | Halliburton | Halliburton | Waived; not preserved as 404(b) error; trial court’s balancing permissible |
| Whether the limiting instruction was proper | Halliburton | Halliburton | Instruction read with some predetermination; error but not fundamental; affirmed |
Key Cases Cited
- Woods v. State, 677 N.E.2d 499 (Ind. 1997) (photographs admissible if relevant and probative despite potential prejudice)
- Butler v. State, 647 N.E.2d 631 (Ind. 1995) (autopsy evidence admissible; identity and cause, etc.)
- Turner v. State, 953 N.E.2d 1039 (Ind. 2011) (habitual offender context and sentencing considerations)
- Brown v. State, 929 N.E.2d 204 (Ind. 2010) (fundamental error standard; exceptional circumstances)
- Mathews v. State, 849 N.E.2d 578 (Ind. 2006) (fundamental error requires egregious due process violation)
- Gill v. State, 730 N.E.2d 709 (Ind. 2000) (contemporaneous objection requirements; waiver of issues)