Elbert Briggs v. State of Indiana (mem. dec.)

CourtIndiana Court of Appeals
DecidedJune 23, 2020
Docket19A-CR-1884
StatusPublished

This text of Elbert Briggs v. State of Indiana (mem. dec.) (Elbert Briggs v. State of Indiana (mem. dec.)) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elbert Briggs v. State of Indiana (mem. dec.), (Ind. Ct. App. 2020).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be FILED regarded as precedent or cited before any Jun 23 2020, 9:21 am court except for the purpose of establishing CLERK the defense of res judicata, collateral Indiana Supreme Court Court of Appeals estoppel, or the law of the case. and Tax Court

ATTORNEY FOR APPELLANT ATTORNEY FOR APPELLEE Mark S. Lenyo Curtis T. Hill, Jr. South Bend, Indiana Attorney General Benjamin J. Shoptaw Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Elbert Briggs, June 23, 2020 Appellant-Defendant, Court of Appeals Case No. 19A-CR-1884 v. Appeal from the St. Joseph Superior Court State of Indiana, The Honorable Appellee-Plaintiff Elizabeth C. Hurley, Judge Trial Court Cause No. 71D08-1811-MR-08

Vaidik, Judge.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-1884 | June 23, 2020 Page 1 of 13 Case Summary [1] Elbert Briggs appeals his conviction for murder, arguing that the trial court

erred by denying his motion for mistrial and by admitting certain evidence. We

disagree and affirm.

Facts and Procedural History [2] Around 3:40 a.m. on June 23, 2018, Eric Phillips pulled into the parking lot of

the Notre Dame boathouse on the St. Joseph River in South Bend. He was

accompanied by Tastacia Parker—Briggs’s on-again/off-again girlfriend.

Shortly after Phillips and Parker arrived, two men approached on foot. After a

brief interaction, one of those two men drew a gun and shot Phillips twice—

once in the chest and once in the arm. Phillips fell in the parking lot and died.

Parker and the other men ran off.

[3] Several months later, the State charged Briggs and Parker with murder. The

State’s theory was that Briggs and Parker wanted to rob Phillips, that Parker got

Phillips to the river for that purpose, and that Briggs was the shooter. Briggs’s

case proceeded to a jury trial in June 2019.1 The State’s evidence was largely

circumstantial but substantial.

1 Parker was charged and prosecuted separately from Briggs. After Briggs was convicted and sentenced, the State dropped the murder charge against Parker in exchange for her plea of guilty to Level 5 felony assisting a criminal and Level 6 felony perjury. She was sentenced to four years in prison and two years of community corrections. See State v. Parker, No. 71D01-1901-MR-1.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-1884 | June 23, 2020 Page 2 of 13 [4] A little over two months before the shooting, on April 12, 2018, Phillips

contacted Parker on Facebook. A few hours later, Parker was messaging with

Briggs and said, “we could poke dude[.]” Ex. 87c. According to Parker, “poke”

means rob. Tr. Vol. II p. 167. Briggs asked, “Who[?]” Ex. 87c. Parker

answered, “He pulled up on me ima drop top and super thirsty he old too . . .

Like 35 I think he said[.]” Id. (Phillips was 37, and Parker testified that “thirsty”

means gullible. Tr. Vol. II p. 166.) Briggs responded, “Ok do that[.]” Ex. 87c.

Parker then asked, “You with me on it[?]” Id. Briggs answered, “Yeah[.]” Id.

[5] Then, on the night of June 22—about eight hours before the shooting—Parker

received the following Facebook message from a friend:

You a grown woman... and you have two kids. We do alot of stupid sh*t but we are NOT RATCHET… that’s bummy af. You 22 years old, if you have to rob anybody while you have a whole ni**a you OBVIOUSLY need to reevaluate your life and the people in it. And any real ni**a would NEVER out his bi*ch in that predicament. He is using you. Kaylin and butter slid in SO MANY ni**as. He never even let me know his moves cause he said that’s not my place period!! You got babies you need to be around for. And you talented af and finished Ross. You can be doing so much more. That’s why I be saying f*** these ni**as. He either gone build you or be yo downfall …aint no in between.

Ex. 87a (emphasis added). Apparently unpersuaded by that message, Parker

started a Facebook conversation with Phillips shortly after midnight. Phillips

said that he was on his way to South Bend, and Parker said, “Let me know

when u make it we can link I’m bored[.]” Ex. 87b. Around 1:00 a.m., Parker

asked Phillips if he wanted to walk by the river and “Smoke n sip[.]” Id.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-1884 | June 23, 2020 Page 3 of 13 [6] At some point Phillips picked Parker up in his car. Cell-phone location records

show that Phillips’s phone, Parker’s phone, and Briggs’s phone were near each

other in the Edison Park area, east of the boathouse, around 3:35 a.m. As

Phillips’s phone approached the boathouse around 3:40 a.m., so did Briggs’s

phone (the location information for Parker’s phone is more limited, but there is

no dispute that she was with Phillips). Phillips was shot just before 3:45 a.m.

Within thirty minutes of the shooting, Briggs’s phone and Parker’s phone were

traveling southeast out of South Bend, toward Fort Wayne. The phones arrived

in Fort Wayne around 6:00 a.m. and were in close proximity to each other at

several points between 6:30 a.m. and 8:00 a.m. Both phones were active in Fort

Wayne for the rest of the day. In the days that followed, the phones traveled

together to West Palm Beach, Florida, where Parker’s father lives. Late on June

24, Briggs sent the following Facebook messages to someone named Quan

Briggs: “I’m gone bro to Florida don’t say sh*t but all I can say is remember the

last place we seen tay bd right hand mans at look that up”; “I love you gone call

when I can”; “That’s why I didn’t come back”; “Bruh real sh*t u got to come

this way when sh*t get right I’m gone be gone until a week[.]” Ex. 203B.

[7] In addition to the Facebook and phone records, the State collected some

physical evidence. Most relevant here, surveillance video from the boathouse

showed the shooting (from a distance—the faces of the participants are not

identifiable), a footprint was found in the mud near Phillips’s car, and a bullet

was lodged in Phillips’s arm.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-1884 | June 23, 2020 Page 4 of 13 [8] Detective Timothy Wiley, the lead investigator, testified about the surveillance

video and three photographs that Parker sent to Briggs via Facebook

approximately nine hours before the shooting. Two of the photographs show

Briggs by himself, wearing a white shirt, dark jeans, and white shoes with

orange or brown soles. See Exs. 88d, 88e. The third photograph show Briggs,

wearing the same outfit, with Parker. See Ex. 88f. Detective Wiley believed the

outfit Briggs was wearing in the photographs “seemed to be the same” as the

outfit the shooter was wearing in the surveillance video. Tr. Vol. III p. 80.

[9] Detective Wiley also testified that after seeing the footprint at the scene and the

Facebook photographs that show Briggs wearing white shoes with orange or

brown soles, he did internet research and found a Fila F-13 shoe, which was

white with an orange sole. Photographs of the Fila shoe and its sole, along with

photographs of the footprint at the scene, were admitted into evidence. Exs. 25,

25a, 25b, 25c, 25d. Detective Wiley testified that he saw “similarities between

the Fila and the footprint,” specifically, a “scalloped edge,” a circle “very close

to that scalloped edge,” another circle on the “other side,” and a “waffle”

pattern “in the middle[.]” Tr. Vol. III pp. 158-59.

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Related

Pittman v. State
885 N.E.2d 1246 (Indiana Supreme Court, 2008)
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Mickens v. State
742 N.E.2d 927 (Indiana Supreme Court, 2001)
McNary v. State
460 N.E.2d 145 (Indiana Supreme Court, 1984)
Pickens v. State
764 N.E.2d 295 (Indiana Court of Appeals, 2002)
Johnson v. State
380 N.E.2d 566 (Indiana Court of Appeals, 1978)
Kavonya Jones v. State of Indiana
101 N.E.3d 249 (Indiana Court of Appeals, 2018)
Jeffrey Fairbanks v. State of Indiana
119 N.E.3d 564 (Indiana Supreme Court, 2019)

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Elbert Briggs v. State of Indiana (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/elbert-briggs-v-state-of-indiana-mem-dec-indctapp-2020.