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Tuesday, April 29, 2014

Ind. Decisions - Supreme Court decides one today, re sufficiency of evidence

In Martin Meehan v. State of Indiana, a 7-page, 5-0 opinion, Justice David writes:

At Martin Meehan’s trial for class C felony burglary, the State offered into evidence, among other things, a glove containing Meehan’s DNA recovered at the scene of the burglary. Meehan was subsequently convicted of class C felony burglary, found to be a habitual offender, and sentenced to a total term of thirteen years in the Indiana Department of Correction. On appeal, he challenges the sufficiency of the evidence underlying his conviction. Finding that Meehan’s jury had before it substantial evidence of probative value from which it could have reasonably inferred that Meehan was guilty of burglary beyond a reasonable doubt, we affirm his conviction. * * *

On appeal, Meehan argued that the State failed to produce sufficient evidence to establish beyond a reasonable doubt that he committed the O.J.S. burglary. Specifically, Meehan contended that it was unreasonable to infer that he committed the burglary “simply because a glove containing his DNA was found at the scene of the crime.” Concluding that “there was no evidence that would support an inference that Meehan’s DNA was found on the glove because he handled it during the burglary, as opposed to some other time,” the Court of Appeals found that the burglary verdict was based on speculation and reversed Meehan’s conviction. * * *

Like a fingerprint, DNA is a marker of identity. Therefore, Meehan’s jury could have found the glove containing Meehan’s DNA, together with other evidence offered by the State, to be sufficient proof of Meehan’s identity as the burglar. Discovered near the damaged overhead door, the glove was located mere steps from the burglar’s point of entry. “A fingerprint found at the point of entry is accorded substantial weight because of its direct relationship to the element of illegal entry.” Id. Thus, the jury could reasonably have inferred that the glove was dropped by Meehan upon entering or exiting the O.J.S. building through the panel of the overhead door he had removed.

Moreover, there was no more obvious explanation for the glove’s presence at the scene. * * *

Meehan also argues that “[t]he [S]tate’s lack of evidence is especially disturbing where police recovered a viable footwear print from a broken door inside the premises and failed to make any comparisons” to his footwear. Whether such a comparison may have helped either side, we will never know. Under Drane, what is required to sustain the verdict is a reasonable inference of guilt drawn from probative evidence. A glove containing Meehan’s DNA discovered at the scene of a burglary just steps from the point of entry and in an area Meehan had no right to be, together with his possession of potential burglary tools, is sufficient evidence to support his conviction for burglary.

Conclusion. Meehan also argues that “[t]he [S]tate’s lack of evidence is especially disturbing where police recovered a viable footwear print from a broken door inside the premises and failed to make any comparisons” to his footwear. (Appellant’s Br. at 9.) Whether such a comparison may have helped either side, we will never know. Under Drane, what is required to sustain the verdict is a reasonable inference of guilt drawn from probative evidence. A glove containing Meehan’s DNA discovered at the scene of a burglary just steps from the point of entry and in an area Meehan had no right to be, together with his possession of potential burglary tools, is sufficient evidence to support his conviction for burglary.

Posted by Marcia Oddi on April 29, 2014 12:50 PM
Posted to Ind. Sup.Ct. Decisions