Michael A. Huff v. State of Indiana (mem. dec.)

CourtIndiana Court of Appeals
DecidedApril 15, 2020
Docket19A-CR-2028
StatusPublished

This text of Michael A. Huff v. State of Indiana (mem. dec.) (Michael A. Huff 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
Michael A. Huff v. State of Indiana (mem. dec.), (Ind. Ct. App. 2020).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), FILED this Memorandum Decision shall not be Apr 15 2020, 8:21 am

regarded as precedent or cited before any CLERK court except for the purpose of establishing Indiana Supreme Court 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 Kay A. Beehler Curtis T. Hill, Jr. Terre Haute, Indiana Attorney General of Indiana

Caroline G. Templeton Deputy Attorney General Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

Michael A. Huff, April 15, 2020 Appellant-Defendant, Court of Appeals Case No. 19A-CR-2028 v. Appeal from the Pulaski Superior Court State of Indiana, The Honorable Crystal A. Kocher, Appellee-Plaintiff. Judge Trial Court Cause No. 66D01-1901-F5-1

Brown, Judge.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-2028 | April 15, 2020 Page 1 of 16 [1] Michael A. Huff appeals his conviction for possessing material capable of

causing bodily injury by an inmate as a level 5 felony and claims the trial court

abused its discretion in admitting evidence and the evidence is insufficient to

sustain his conviction. We affirm.

Facts and Procedural History

[2] In January 2019, Huff was an inmate in the Pulaski County Jail. On January

14 or 15, 2019, Pulaski County Sheriff’s Sergeant of Corrections Christopher

McAninch conducted a C.A.B. hearing, which is “basically just a committee

hearing board for disciplinary,” with Huff in a cell for attorney visitation.

Transcript Volume II at 141. Sergeant McAninch wore a body camera during

the hearing in order to record Huff’s “testimony and everything else for [the]

C.A.B. hearing.” Id. at 144.

[3] After concluding the hearing, Sergeant McAninch called the pod control officer

to unlock the door. The locking mechanism for the door slid open, and Huff

proceeded to open the door quickly and then closed the door quickly in front of

Sergeant McAninch, locking him inside the visitation room.

[4] Huff moved down the hallway past the dispatch center. Sergeant McAninch

tried to radio to unlock the door and observed an officer hurry to the control

panel to unlock the door. He walked out of the room and yelled Huff’s name.

Huff stopped, hesitated for a second, and then started walking towards him.

Sergeant McAninch placed Huff into a holding cell, and Huff kicked the door

Court of Appeals of Indiana | Memorandum Decision 19A-CR-2028 | April 15, 2020 Page 2 of 16 after being placed inside. Huff “started to attempt to tear his mat apart” and

“stuff things in the toilet.” Id. at 148.

[5] Sergeant McAninch went to Huff’s old cell and noticed his sleeping mat was

“very heavy.” Id. at 149. After a metal detector alerted on the mat, Sergeant

McAninch noticed the mat was hand sewn with white string material, cut open

the mat, and discovered what looked like the blackened end of a paperclip. The

officers decided to use a metal detector on the remainder of Huff’s belongings.

Sergeant McAninch discovered an envelope that was “sealed pretty tight” with

the name Braden Huff on it and felt a stiff object in the envelope that would not

bend as easily as paper. Id. at 152. He opened the envelope and discovered

handwritten letters dated November 2018 from a female inmate located in the

facility, a piece of toilet paper, and a razor blade. Sergeant McAninch

completed a contraband confiscation form and reviewed the form with Huff.

[6] On January 17, 2019, the State charged Huff with possessing material capable

of causing bodily injury by an inmate as a level 5 felony. Huff waived his right

to counsel. At the jury trial, when asked how he was acquainted with Huff,

Sergeant McAninch answered without objection: “[T]hrough several incidences

inside the jail . . . . From when I first started here, um, several incidences in

which I was personally involved in, um, through physical incidences with him,

um, dealing with his C.A.B. hearings from other staff in which he has had

disciplinary problems with.” Id. at 140. Sergeant McAninch also testified

without objection: “At the time, he was actually serving a disciplinary sanction

in our disciplinary block.” Id. at 143.

Court of Appeals of Indiana | Memorandum Decision 19A-CR-2028 | April 15, 2020 Page 3 of 16 [7] During Sergeant McAninch’s testimony, the prosecutor asked to display the

first video from the bodycam. Huff objected and asserted the video was not

relevant to the facts of the charge. The court overruled the objection, found that

“it is relevant based on the fact that it is foundation for the offense that

occurred,” and marked the disc containing the bodycam footage as State’s

Exhibit 1. Id. at 146. The first video consisted of a seventy-three second clip

showing the end of the C.A.B. hearing in which Huff exited the room, closed

the door, walked away from Sergeant McAninch, and stated he was going back

to the block in a reasonable manner. The video includes an abrupt sound after

Huff was placed in a holding cell and a statement by Sergeant McAninch telling

him to quit hitting the door.

[8] The prosecutor later asked to publish the second video showing the search of

the envelope. When the court asked Huff if he had any objection to the

publication of the second video, Huff answered in the negative. The court

published the second video on State’s Exhibit 1 to the jury. This 125-second

video showed the wanding of the envelope by a metal detector and Sergeant

McAninch feeling and opening the envelope.

[9] Sergeant McAninch testified that possessing razors constitutes a “very high

security risk, as well as a safety concern for both inmates and staff.” Id. at 157.

When asked the reason, he answered:

There is [sic] multiple concerns when it comes into it, whether it be dangerous because it could be easily affixed to a handle, whether you take a toothbrush, get it hot enough to where the

Court of Appeals of Indiana | Memorandum Decision 19A-CR-2028 | April 15, 2020 Page 4 of 16 plastic becomes moldy, it can be affixed in there. It can be attached to pencils, and the blade is, now has a longer handle on it. It could be used more as a slashing tool, um, as well as some inmates could potentially use it for a suicide attempt.

Id. at 158.

[10] Without objection, the court admitted a third video on State’s Exhibit 1

containing the video of the review of the contraband confiscation form. In the

five-minute video, Sergeant McAninch reviewed the form with Huff and

indicated he found a paperclip in the sleeping mat and a razor blade in an

envelope. Huff asked about his pillow, and Sergeant McAninch indicated it

was destroyed because it was handsewn on the top and was alerting on the

metal detector and stated, “I already found a paperclip in the mat and then I’m

finding razorblades in the other stuff.” State’s Exhibit 1. Huff stated: “There

shouldn’t have been no razorblades in no other stuff.” Id. Huff also stated that

the envelope had been sealed for months. The video revealed Huff stating there

was no reason to take the mail and the envelope and Sergeant McAninch

stating it was all seized for evidence and this was going to be an ongoing

investigation.

[11] On cross-examination, Huff asked if there had ever been a report of him

intimidating someone with a razor blade, and Sergeant McAninch answered

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