Kenneth D. Ratliff v. State of Indiana

CourtIndiana Court of Appeals
DecidedAugust 26, 2024
Docket24A-CR-00107
StatusPublished

This text of Kenneth D. Ratliff v. State of Indiana (Kenneth D. Ratliff v. State of Indiana) 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
Kenneth D. Ratliff v. State of Indiana, (Ind. Ct. App. 2024).

Opinion

FILED Aug 26 2024, 9:09 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Kenneth Ratliff, Appellant-Defendant

v.

State of Indiana, Appellee-Plaintiff

August 26, 2024 Court of Appeals Case No. 24A-CR-107 Appeal from the Porter Superior Court The Honorable Jeffrey W. Clymer, Judge Trial Court Cause No. 64D02-2104-F2-3540

Opinion by Judge Mathias Judges Riley and Felix concur.

Court of Appeals of Indiana | Opinion 24A-CR-107 | August 26, 2024 Page 1 of 18 Mathias, Judge.

[1] Kenneth Ratliff appeals his convictions for Level 3 felony burglary, Level 3

felony rape, and Class A misdemeanor battery. He also appeals his sentence.

Ratliff raises three issues for our review, which we restate as follows:

1. Whether the trial court clearly erred when it concluded that the prosecutor did not intentionally “goad” Ratliff into moving for a mistrial.

2. Whether Ratliff’s conviction for Class A misdemeanor battery is contrary to Indiana’s protection against substantive double jeopardy.

3. Whether Ratliff’s sentence is inappropriate in light of the nature of the offenses and his character.

[2] We affirm in part, reverse in part, and remand with instructions for the trial

court to vacate Ratliff’s conviction and sentence for Class A misdemeanor

battery.

Facts and Procedural History [3] In the spring of 2020, J.B. met Ratliff through a mutual friend. Ratliff stopped

by J.B.’s apartment in Valparaiso a couple of times per month to give the

mutual friend a ride. Ratliff visited J.B.’s apartment about five times.

[4] In the early morning hours of April 15, 2021, J.B. woke to the sound of loud

banging on her front door. J.B. went downstairs, looked out a window next to

Court of Appeals of Indiana | Opinion 24A-CR-107 | August 26, 2024 Page 2 of 18 the front door, and yelled, “Who’s out there?” Tr. Vol. 5, p. 169. Ratliff

responded, “Ken.” Id. J.B. recognized Ratliff’s voice.

[5] J.B. told Ratliff “to leave and go home.” Id. at 170. Ratliff then punched

through the window where J.B. was standing, reached inside her apartment,

and unlocked the front door. He cut his forearm in the process. J.B. was

screaming, and Ratliff told her to “Shut up.” Id. at 171. He then grabbed her

and forced her back up the stairs to her bedroom. While doing so, he was

hitting J.B.’s head and face.

[6] In her bedroom, Ratliff “pushed” J.B. down onto her bed and removed her

pants and underwear. Id. at 172. Ratliff pulled his pants down, and then he

raped her. About an hour later, he fell asleep. Once Ratliff was asleep, J.B.

escaped from her bedroom, grabbed her phone, and hid inside a closet. From

inside the closet, she called police.

[7] Valparaiso Police Department Officers Peter Castillo and Matthew Zavacki

were the first to respond to the scene. J.B. met them near her front door, where

they observed the broken window along with glass on the ground. The officers

also observed drops of blood going up the stairs. And, in J.B.’s bedroom, they

caught Ratliff with his pants down while he was still asleep in the bed. Officer

Castillo also noticed that Ratliff had a fresh wound on his right arm that was

bleeding. The officers arrested Ratliff.

Court of Appeals of Indiana | Opinion 24A-CR-107 | August 26, 2024 Page 3 of 18 [8] J.B. was transported to a nearby hospital and examined. She had injuries to her

face and head as well as to her genitals. A DNA analysis identified Ratliff’s

DNA in samples taken from, on, and in J.B.’s body.

[9] The State charged Ratliff in relevant part with Level 3 felony burglary, Level 3

felony rape, and Class A misdemeanor battery. Specifically, the last-amended

information stated as follows:

Count I Burglary (Level 3 Felony) I.C. 35-43-2-1(2)

. . . Kenneth Ratliff . . . on or about April 15, 2021, did break and enter the building or structure of Victim #1 . . . with intent to commit a felony of in [sic] it and resulted in bodily injury to Victim #1 . . . .

Count II Rape (Level 3 felony) I.C. 35-42-4-1(a)(1)

. . . Kenneth Ratliff . . . on or about April 15, 2021, did knowingly or intentionally have sexual intercourse with Victim #1 . . . when Victim #1 was compelled by force or imminent threat of force . . . .

***

Count IV Battery (A Misdemeanor) I.C. 35-42-2-1(d)(1)

Court of Appeals of Indiana | Opinion 24A-CR-107 | August 26, 2024 Page 4 of 18 . . . Kenneth Ratliff . . . on or about April 15, 2021, did knowingly or intentionally touch Victim #1 in a rude, insolent, or angry manner and resulted in bodily injury to Victim #1 . . . .

Appellant’s App. Vol. 2, pp. 77-78 (bold, underlining, and capitalization

removed).

[10] In September 2023, the State filed two notices of intent to introduce evidence

under Indiana Evidence Rules 404(b) and 412(c) regarding a prior alleged rape

of J.B. by Ratliff in August 2020. Ratliff also filed a notice of intent to introduce

that same evidence under Rule 412(c). The trial court held a hearing on the

admissibility of any such evidence, after which the court ordered as follows:

Prior [s]exual conduct with the Defendant, including the previous alleged Rape[:] the State argues that the alleged conduct is admissible under Indiana Rule of Evidence 404(b) [as] lack of mistake, etc. The Defendant argues it is admissible for impeachment under [Rule] 608. The Court finds that the Defendant may not introduce the evidence to impeach unless the State first introduces testimony. (Opens the door[.]) The Defendant did not argue . . . that he seeks to introduce the evidence . . . to prove consent. The evidence of alleged sexual conduct only with the Defendant may be introduced by the State under [Rule] 412(b)(1)(B).

Id. at 88.

[11] Thereafter, Ratliff’s jury trial began. In his opening statement, the prosecutor

outlined the expected witness testimony. In doing so, the prosecutor stated that,

in speaking with a detective about the April 15, 2021, events, J.B. told the

detective “of another scenario where Ken had raped her.” Tr. Vol. 3, p. 64. Court of Appeals of Indiana | Opinion 24A-CR-107 | August 26, 2024 Page 5 of 18 Ratliff objected and moved for a mistrial on the ground that that “statement is

very, very damning, Judge.” Id. The prosecutor responded: “My understanding

of your ruling was that . . . [,] if the State chooses to put that into evidence, that

it’s admissible.” Id. The trial court overruled Ratliff’s objection and request for a

mistrial, stating “the State may introduce that evidence.” Id. The prosecutor

then told the jury: “You’ll hear about this earlier report that [J.B.] made that the

same Ken was in her apartment and raped her in August 2020,” but, because

“Ken’s last name was unknown at that time . . . and [J.B.] did not wish to

pursue charges due to fear of retaliation[,] . . . that case was dropped.” Id. at 65.

The prosecutor concluded his opening statement by stating that the instant

charges would be “about an allegation in April of 2021 and an allegation in

August of 2020.” Id. at 66.

[12] The next morning, the trial court opened the proceedings by informing counsel

that the court had reviewed the transcript of the prosecutor’s opening statement.

The court asked the prosecutor: “Aren’t you . . . trying to argue [to] find him

guilty this time because he wasn’t found guilty last time he raped her?” Tr. Vol.

4, p. 3. The prosecutor responded that he was “not arguing that” and that,

when J.B.

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