966 N.E.2d 780
Ind. Ct. App.2012Background
- Woodson filed a post-conviction petition claiming ineffective assistance of trial counsel.
- Police stopped a rental car after a speeding violation; driver Onyeji had a handgun in the glove compartment.
- Woodson was listed as an additional driver on the rental agreement and claimed to have paid cash and driven the car.
- The trunk search, consent to search, and discovery of cocaine and a gun led to multiple felony convictions.
- Woodson moved to suppress the evidence; the trial court denied suppression and Woodson was convicted on several counts.
- PCR court denied Woodson’s petition; on appeal, the court affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did trial counsel err by not objecting to evidence from the rental-car search? | Woodson: trial counsel failed to preserve issue for appeal. | State: suppression issue was non-prejudicial and properly decided. | No reversible error; no prejudice shown. |
| Did continued detention and investigation violate Article I, Section 11? | Woodson: prolonged detention breached Indiana Constitution. | Woodson: evidence supports reasonable suspicion and detention was justified. | Detention reasonable under totality of circumstances. |
| Was Woodson's consent to search valid under the Fourth Amendment? | Woodson: lack of actual/apparent authority invalidates consent. | State: Woodson had no reasonable privacy interest; consent valid. | Consent valid; no ineffective-assistance finding. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong ineffective assistance test)
- Matlock, 415 U.S. 164 (U.S. 1974) (third-party consent when shared property)
- Rodriguez, 497 U.S. 177 (U.S. 1990) (apparent authority to consent governs searches)
- Krise v. State, 746 N.E.2d 957 (Ind. 2001) (privacy interests and Fourth Amendment scope in Indiana)
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (totality-of-the-circumstances test for searches/seizures)
- Moran v. State, 644 N.E.2d 536 (Ind.1994) (Indiana independent interpretation of search-and-seizure clause)
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (consent to search must be voluntary and knowing)
- Stallings v. State, 508 N.E.2d 550 (Ind.1987) (indiana standards for consent to search)