Luther Riddell v. State of Indiana (mem. dec.)

CourtIndiana Court of Appeals
DecidedFebruary 29, 2016
Docket34A04-1507-CR-897
StatusPublished

This text of Luther Riddell v. State of Indiana (mem. dec.) (Luther Riddell 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
Luther Riddell v. State of Indiana (mem. dec.), (Ind. Ct. App. 2016).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this Memorandum Decision shall not be Feb 29 2016, 9:19 am

regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral estoppel, or the law of the case.

ATTORNEY FOR APPELLANT ATTORNEYS FOR APPELLEE Donald E.C. Leicht Gregory F. Zoeller Kokomo, Indiana Attorney General of Indiana

Eric P. Babbs Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Luther Riddell, February 29, 2016 Appellant-Defendant, Court of Appeals Case No. 34A04-1507-CR-897 v. Appeal from the Howard Superior Court State of Indiana, The Honorable George A. Appellee-Plaintiff. Hopkins, Judge Trial Court Cause No. 34D04-1412-MR-171

Altice, Judge.

Case Summary

Court of Appeals of Indiana | Memorandum Decision 34A04-1507-CR-897 | Februar 29, 2016 Page 1 of 9 [1] Luther Riddell was convicted of Murder,1 a felony, and was determined to be a

Habitual Offender. Riddell presents two issues for our review:

1. Did the trial court abuse its discretion in denying Riddell’s motion for a mistrial?

2. Did the trial court abuse its discretion in admitting certain evidence during the habitual offender phase?

[2] We affirm.

Facts & Procedural History

[3] During the early morning hours of December 16, 2014, Jay West went to

Riddell’s house. An argument and fight ensued, most of which was recorded

on Riddell’s surveillance camera system. As West walked away from Riddell’s

home and out of camera range, Riddell grabbed an object and followed him.

Riddell then returned to camera range and replaced the object. West was

discovered lying in a nearby yard and ultimately died of a stab wound. West’s

DNA was taken from the blade of a knife that was found in proximity to where

Riddell can be seen grabbing and later replacing an object.

[4] The following day, the State charged Riddell with murder and alleged him to be

a habitual offender. A three-day jury trial commenced on June 9, 2015. At the

end of the second day, just before the court recessed for the evening, there was

1 Ind. Code § 35-42-1-1(1).

Court of Appeals of Indiana | Memorandum Decision 34A04-1507-CR-897 | Februar 29, 2016 Page 2 of 9 an outburst from the gallery by an unidentified woman who yelled, “You need

to fucking die, you fucking murderer, lying ass, bitch.” Transcript at 213. The

trial court summoned security and removed the jury to the jury room. The

record continued outside the presence of the jury with Riddell’s counsel moving

for a mistrial based on the spectator’s outburst. Riddell’s counsel argued that

“the jury has been affected and may have been tainted and contaminated.” Id.

at 214. The trial court denied the motion for mistrial and Riddell’s counsel

made no further request.

[5] The jury reconvened the next day and the trial continued. After the close of

evidence, the jury returned its verdict finding Riddell guilty of murder. The trial

then continued with the habitual offender phase tried to the jury. To establish

Riddell was a habitual offender, the State offered State’s Exhibit 19, a series of

documents relating to his August 15, 2008 conviction for receiving stolen

property, a class D felony, under Cause No. 34D04-0710-FD-141. Riddell

objected to admission of State’s Exhibit 19, asserting that not every document

therein was certified. The trial court looked at the exhibit and sua sponte

removed four pages of the exhibit, which were described as a “prosecutor’s

report” and an “update report.” Transcript at 275. The trial court allowed

admission of the remaining documents that comprised State’s Exhibit 19,

including the certified charging information, certified probable cause affidavit,

and certified sentencing order from Cause No. 34D04-0710-FD-141. The trial

court overruled Riddell’s objection that the exhibit must be “taken either as a

whole or not.” Transcript at 276.

Court of Appeals of Indiana | Memorandum Decision 34A04-1507-CR-897 | Februar 29, 2016 Page 3 of 9 [6] When the State offered State’s Exhibit 21, which included documents relating to

Riddell’s April 25, 2006 conviction for burglary, a class C felony, under Cause

No. 30D01-0512-FC-185, Riddell objected, citing again the fact that several of

the documents included therein were not certified. The trial court sua sponte

took out the probable cause affidavit, but allowed admission of the remaining

documents, which included the certified charging information, certified guilty

plea and sentencing entry, and certified judgment of conviction from Cause No.

30D01-0512-FC-185. The trial court overruled Riddell’s objection that the

exhibit “ha[d] to be accepted in whole or rejected.” Transcript at 278. The jury

found Riddell to be a habitual offender. On July 10, 2015, the trial court

sentenced Riddell to sixty years for murder with a ten-year enhancement for his

status as a habitual offender. Riddell now appeals.

Discussion & Decision

1. Mistrial

[7] Riddell argues that the trial court abused its discretion in denying his motion for

a mistrial following an outburst from someone in the gallery while the jury was

still present in the courtroom. Riddell asserts that the trial court’s failure to

admonish the jury immediately after the outburst occurred allowed the outburst

“to germinate in [the jurors’] minds.” Appellant’s Brief at 4. Riddell also

seemingly faults the trial court for not admonishing the jury the following

morning before trial resumed.

Court of Appeals of Indiana | Memorandum Decision 34A04-1507-CR-897 | Februar 29, 2016 Page 4 of 9 [8] A mistrial is an extreme action and is warranted only when no other action can

be expected to remedy the situation. Vaughn v. State, 971 N.E.2d 63, 68 (Ind.

2012). “The decision to grant or deny a mistrial motion is left to the sound

discretion of the trial court.” Id. at 67. We will reverse the trial court’s

determination on the issue only for an abuse of discretion, which occurs when

the trial court’s decision is clearly against the logic and effect of the facts and

circumstances before the court. Id. at 67-68. “We afford great deference to the

trial court because it is in the best position to gauge the circumstances and

impact on the jury.” Id.

[9] When faced with a circumstance that a defendant believes might warrant a

mistrial, generally the correct procedure is to request an admonishment. Isom v.

State, 31 N.E.3d 469, 482 (Ind. 2015). If unsatisfied with the admonishment or

if it is obvious that an admonishment will not be sufficient to cure the error,

then counsel may move for a mistrial. Id. In situations similar to the present, it

has been held that an admonishment to disregard an outburst by a spectator is a

reasonably curative measure. Thus, where an admonishment is given in such

cases, the trial court’s subsequent denial of a motion for mistrial is not an abuse

of discretion. See Adkins v. State, 524 N.E.2d 1274, 1275 (Ind. 1988); Hill v.

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Related

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817 N.E.2d 239 (Indiana Court of Appeals, 2004)
Townsend v. State
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Gregory v. State
540 N.E.2d 585 (Indiana Supreme Court, 1989)
Hill v. State
497 N.E.2d 1061 (Indiana Supreme Court, 1986)
Jackson v. State
758 N.E.2d 1030 (Indiana Court of Appeals, 2001)
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736 N.E.2d 801 (Indiana Court of Appeals, 2000)
Kevin Charles Isom v. State of Indiana
31 N.E.3d 469 (Indiana Supreme Court, 2015)
Adkins v. State
524 N.E.2d 1274 (Indiana Supreme Court, 1988)

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