William Clyde Gibson III v. State of Indiana
2016 Ind. LEXIS 264
| Ind. | 2016Background
- William Clyde Gibson III pleaded guilty to murdering Stephanie Kirk and was sentenced to death after a four-day sentencing hearing.
- Gibson later murdered Christine Whitis; the Whitis murder is referenced as the basis for aggravator considerations.
- The State charged four aggravating factors to support the death penalty and moved to amend one aggravator on the eve of guilt-plea.
- On the Kirk case, Gibson pled guilty and waived a jury for the penalty phase; the court would determine death vs. life.
- The State amended Aggravator 3 from ‘another murder’ to ‘convicted of another murder,’ which the court permitted.
- The trial court weighed aggravators and mitigators, ultimately concluding death was the appropriate sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of aggravators 1 and 2 | Gibson argues insufficient evidence Kirk was alive during deviate conduct. | State contends substantial evidence shows pre-death force and alive victim during act. | Aggravators proven beyond a reasonable doubt. |
| Fundamental error from amendment | Amendment prejudiced substantial rights and violated due process. | Amendment did not prejudice rights; proper notice and opportunity to defend existed. | Amendment not fundamental error; properly allowed. |
| Weighting of aggravators and mitigators | Trial court abused discretion by misweighing mitigating and aggravating factors. | Court properly weighed factors; deference due to sentencing decision. | No manifest abuse of discretion; weightings upheld. |
| Proportionality of death sentence | Sentence may be inappropriate given character and nature of offense. | Court appropriately considered records, history, remorse, and mitigating evidence. | Death sentence not inappropriate; affirmed. |
Key Cases Cited
- Bieghler v. State, 481 N.E.2d 78 (Ind. 1985) (sufficiency standard in capital cases; substantial evidence standard)
- Erkins v. State, 13 N.E.3d 400 (Ind. 2014) (notice and opportunity to be heard in amendments)
- Knapp v. State, 9 N.E.3d 1289 (Ind. 2012) (probation aggravator and nexus considerations)
- Covington v. State, 842 N.E.2d 345 (Ind. 2006) (manifest abuse standard in weighing aggravators/mitigators)
- Cardwell v. State, 895 N.E.2d 1219 (Ind. 2008) (proportionality and review in death sentences)
- Reid v. State, 876 N.E.2d 1114 (Ind. 2007) (Appellate Review framework for capital sentences)