Jeffrey Dean Needler v. State of Indiana (mem. dec.)

CourtIndiana Court of Appeals
DecidedJuly 15, 2019
Docket19A-CR-15
StatusPublished

This text of Jeffrey Dean Needler v. State of Indiana (mem. dec.) (Jeffrey Dean Needler 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
Jeffrey Dean Needler v. State of Indiana (mem. dec.), (Ind. Ct. App. 2019).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), FILED this Memorandum Decision shall not be Jul 15 2019, 6:44 am

regarded as precedent or cited before any CLERK Indiana Supreme Court court except for the purpose of establishing Court of Appeals and Tax Court the defense of res judicata, collateral estoppel, or the law of the case.

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Russell B. Cate Curtis T. Hill, Jr. Cate, Terry & Gookins LLC Attorney General of Indiana Carmel, Indiana Samuel J. Dayton Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Jeffrey Dean Needler, July 15, 2019 Appellant-Defendant, Court of Appeals Case No. 19A-CR-15 v. Appeal from the Hamilton Superior Court State of Indiana, The Honorable J. Richard Appellee-Plaintiff. Campbell, Judge Trial Court Cause No. 29D04-1709-F6-6656

Robb, Judge.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-15 | July 15, 2019 Page 1 of 9 Case Summary and Issue [1] Following a jury trial, Jeffrey Needler was found guilty of assisting a criminal, a

Level 6 felony, and sentenced to 365 days in the Indiana Department of

Correction, with 305 days suspended. Needler appeals his conviction, raising

one issue for our review: whether the trial court committed fundamental error

by admitting evidence resulting from an allegedly unconstitutional search of

Needler’s residence. Concluding Needler’s claim does not assert fundamental

error, we affirm.

Facts and Procedural History [2] On September 8, 2017, Deputies Jeffrey Wright and Todd Green from the

Hamilton County Sheriff’s Department went to a home on Chestnut Street in

Noblesville, Indiana, to serve an arrest warrant on Joshua Needler. A man

identifying himself as Joshua’s grandfather greeted the officers and told them

that Joshua was not at that address but was staying with Needler, Joshua’s

uncle, at an address on Cicero Road. In 2016, law enforcement had served an

arrest warrant on Joshua at that Cicero Road address and found him hiding

under a bed.

[3] Deputies Wright and Green then went to the Cicero Road address. Three other

officers, including Deputy Ryan Meier, joined them because a “fairly typical”

way of serving an arrest warrant is to have multiple officers on scene where “a

couple [of officers] will go to the door, try to make contact at the door, then one

Court of Appeals of Indiana | Memorandum Decision 19A-CR-15 | July 15, 2019 Page 2 of 9 or two will go to the back, just to make sure someone doesn’t run out the back.”

Transcript of Evidence, Volume 2 at 70-71. Deputy Meier, with Deputy Wright

backing him up, knocked on the door of the trailer and after several minutes

passed during which the officers could hear movement and voices from inside,

Needler answered. Officer Meier advised Needler that they were there looking

for Joshua. Needler told him Joshua was not there and that he had not seen

him for a couple of days.

[4] Because of the “totality of circumstances, the amount of time it took to answer

the door, the rustling in there, the previous history that Joshua had been there

and hid in the back,” officers did not accept Needler’s answer at face value but

continued to talk with him for approximately ten minutes. Id. at 94. Officer

Meier asked Needler if he would allow officers into the residence to search for

Joshua. Needler said “that he could not give [officers] permission because he

did not own the trailer.” Id. at 73. Officers explained multiple times that if

Needler lived there, he could give them permission to enter but he still refused.

Officers asked “[t]wo, three, four” times if Joshua was in the trailer. Id. at 74.

Officer Meier told Needler that he thought Joshua was in the trailer and also

told him that if he could prove Joshua was there, he would take Needler to jail

for assisting a criminal.

[5] After repeated questioning, Needler finally admitted Joshua was “probably” in

the trailer. Officer Meier said, “there’s no probably or probably not. You

should know whether he’s in there or not. And if he’s in there, you need to let

us in to go get him.” Id. at 96. Eventually, Needler allowed officers into the

Court of Appeals of Indiana | Memorandum Decision 19A-CR-15 | July 15, 2019 Page 3 of 9 trailer and said, “follow me.” Id. As Needler led officers directly to a bedroom

in the back of the trailer, he announced, “[T]hey’re coming in, come on out.”

Id. Officers found Joshua hiding under blankets in a closet. Joshua was taken

into custody on the arrest warrant.

[6] Officers then “had further discussion” with Needler, id. at 75, pointing out “that

he had denied [them] access and that he could have given [them] access

immediately and [they] didn’t need to debate over it at the beginning[,]” id. at

100. Needler claimed he was just protecting family. After Deputy Meier

confirmed that the circumstances in 2016 when Joshua was found at the trailer

were virtually identical, Deputy Meier took Needler into custody because “last

time . . . they did not charge him with aiding even though they could have [and]

I decided that since this was the second time I was going to arrest him for

aiding a criminal.” Appellant’s Appendix, Volume II at 15.

[7] The State charged Needler with assisting a criminal, a Level 6 felony, for

harboring, concealing, or assisting Joshua, “a person who has committed Theft

as a Level 6 Felony, with the intent to hinder [his] apprehension or

punishment” while “not standing in the relationship of parent, child, or spouse”

to Joshua. Id. at 12; see Ind. Code § 35-44.1-2-5. A jury found Needler guilty as

charged. Needler now appeals his conviction.

Discussion and Decision

Court of Appeals of Indiana | Memorandum Decision 19A-CR-15 | July 15, 2019 Page 4 of 9 [8] Needler contends the trial court committed fundamental error “by allowing

evidence of law enforcement’s entrance into a trailer to be admitted at trial” in

violation of his federal and state constitutional rights. Appellant’s Brief at 5.

I. Standard of Review [9] It is unclear exactly what evidence Needler claims the trial court erroneously

admitted. Nonetheless, he tacitly acknowledges that he did not object to the

admission of any evidence at trial. See Appellant’s Br. at 8-9 (stating standard

of reviewing a claim of fundamental error). A contemporaneous objection is

required to preserve evidentiary error on appeal, and the failure to timely object

generally forfeits the issue for purposes of appellate review. Hastings v. State, 58

N.E.3d 919, 922 (Ind. Ct. App. 2016). To avoid this, Needler contends the

admission of evidence was fundamental error.

[10] A claim that has been forfeited by a defendant’s failure to raise a

contemporaneous objection can be reviewed on appeal if the reviewing court

determines that a fundamental error occurred. Brown v. State, 929 N.E.2d 204,

207 (Ind. 2010). The fundamental error exception is “extremely narrow[.]”

Mathews v. State, 849 N.E.2d 578, 587 (Ind. 2006). Fundamental error allows us

to “address an error that made a fair trial impossible or constituted a clearly

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Brown v. State
929 N.E.2d 204 (Indiana Supreme Court, 2010)
Mathews v. State
849 N.E.2d 578 (Indiana Supreme Court, 2006)
State v. Barker
734 N.E.2d 671 (Indiana Court of Appeals, 2000)
Daniel Brewington v. State of Indiana
7 N.E.3d 946 (Indiana Supreme Court, 2014)
J.K. v. State of Indiana
8 N.E.3d 222 (Indiana Court of Appeals, 2014)
Richard Vance Hastings v. State of Indiana (mem. dec.)
58 N.E.3d 919 (Indiana Court of Appeals, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Jeffrey Dean Needler v. State of Indiana (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffrey-dean-needler-v-state-of-indiana-mem-dec-indctapp-2019.