Miguel Tyler, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2025)

MEMORANDUM DECISION

Statement of the Case

[1] Miguel Tyler was at a cookout when Antonio Lawrence started arguing with Tyler's friends. Tyler drew a firearm and started shooting at Lawrence, emptying the clip but failing to hit anyone. Tyler was later arrested. During a custodial interrogation, Tyler admitted to shooting his gun until the clip was empty. Tyler was charged with attempted battery with a deadly weapon, felony criminal recklessness, felony unlawful carrying of a handgun, and felony pointing a firearm. At trial, the State read Lawrence's prior deposition testimony into evidence because Lawrence did not appear for the trial. Tyler was found guilty as charged. Tyler now appeals and presents a single issue for our review: Whether the trial court abused its discretion by admitting certain evidence.

[2] We affirm.

Facts and Procedural History

[3] On July 26, 2023, Tyler was helping some friends move furniture into an apartment at the Cambridge Estates complex in Tippecanoe County, Indiana. After they arrived, Tyler and his friends walked over to a nearby cookout. While they were at the cookout, Lawrence approached the group, argued, and “cussed ․ out” Tyler's friend Roseanne Adams. Tr. Vol. II at 180. Adams began to walk away, but Lawrence “was still having more words.” Id. Things “got heated” because others started arguing with Lawrence, including Tyler. Id. at 181. Then, Tyler pulled out a firearm and “just started firing shots everywhere.” Id. at 181–82. Tyler “just shot randomly,” id. at 161, and fired “until the gun was completely empty,” id. at 162. After Tyler stopped shooting, he and his friends hid in the hallway of one of the apartment buildings. There, Tyler started swinging the gun around and said, “somebody better get me the F out of here before the cops get here.” Id. at 184. Shortly thereafter, Adams drove away from the scene with Tyler and his friends.

[4] Law enforcement officers were able to identify Tyler as the shooter, and Tyler was arrested the following morning. Officers transported Tyler to the police station where Detective Sinks of Lafayette Police Department began to interrogate Tyler. At the start of the interrogation, Detective Sinks read Tyler his Miranda rights, and Tyler verbally acknowledged that he understood his rights. Tyler told Detective Sinks his version of the events of the previous night. According to Tyler, once the argument between Lawrence and his friends escalated, Tyler “lost [his] mind, ․ blanked out, and just started shooting.” Id. at 24:02–24:06. Tyler admitted that he fired all 12 rounds in his gun during the shooting. Tyler also said that he was “mentally f*cked up in the head” because he had previously been shot at and watched his brother die. Id. at 24:35–24:42. A few minutes later, Tyler admitted that he had been taking “psych meds and stuff,” id. at 32:48–32:51, but when Detective Sinks asked about the specific medication, Tyler replied, “I haven't been taking it for a minute,” id. at 33:09–33:11.

[5] Later in the questioning, Detective Sinks asked Tyler about the location of the gun. Tyler initially said he did not know where the gun was because he threw it out of Adams's car during the ride away from Cambridge Estates. After Detective Sinks stressed the importance of finding the gun, Tyler agreed to help locate the gun. The entire interrogation lasted less than an hour.

[6] The State charged Tyler with attempted battery with a deadly weapon as a Level 5 felony, criminal recklessness as a Level 5 and Level 6 felony, unlawful carrying of a handgun as a Level 5 felony, and pointing a firearm as a Level 6 felony. In April 2024, Tyler conducted a deposition of Lawrence. During his deposition, Lawrence testified that on the day of the incident, he was walking through Cambridge Estates when he started arguing with a “lady” who was with “some young guys” that he thought were “intoxicated.” Tr. Vol. III at 166. While he was talking to the lady, Lawrence heard gunshots, “took off,” and “[d]idn't look back.” Id. at 168. Lawrence testified that he did not “have any idea” of who fired the shots or “where they came from.” Id. at 167. Further, Lawrence stated, “I didn't see no shots, nobody, no gunfire, no spark or none of that.” Id.

[7] On May 17, Tyler filed a motion to suppress the admissions he made during the custodial interrogation, alleging his admissions were not voluntary because he was, “stressed, suicidal, was experiencing mental problems, [ ] not eating ․ was extremely weak, and he felt as if he would collapse ․ was sleepy, thirsty, [and] hungry” during questioning. Appellant's Br. at 11. After a hearing, the trial court denied Tyler's motion. A jury trial was held, and the State offered the video of Tyler's confession to Detective Sinks into evidence. Tyler objected, renewing the arguments made in his motion to suppress; the trial court admitted a redacted version of the video over Tyler's objection.

[8] Later in the trial, after it was evident that Lawrence was not going to attend the trial, the State offered Lawrence's deposition testimony into evidence. Outside the presence of the jury, the State called its investigator Nathan Brown to testify regarding Lawrence's unavailability. Brown testified that, less than three weeks before the trial, he left a subpoena at Lawrence's home and subsequently spoke with him twice on the phone, confirming receipt of the subpoena. After Lawrence initially failed to appear, Brown attempted to call Lawrence six times and asked another investigator to leave an additional copy of the subpoena at Lawrence's home. The trial court determined that the State showed it made a reasonable effort to secure Lawrence's appearance and allowed the State to read Lawrence's deposition testimony into the record. Tyler was found guilty as charged and received an aggregate sentence of five years of incarceration. Tyler now appeals.

Discussion and Decision

The Trial Court Did Not Abuse Its Discretion by Admitting Certain Evidence at Trial

[9] Tyler claims that the trial court erred in admitting certain evidence at trial. We review rulings on admissibility of evidence for an abuse of discretion. Russell v. State, 234 N.E.3d 829, 858 (Ind. 2024) (quoting Conley v. State, 972 N.E.2d 864 (Ind. 2012)), cert. denied. “[W]e may affirm the trial court's decision on any basis supported by the record,” Means v. State, 201 N.E.3d 1158, 1163 (Ind. 2023) (citing Ramirez v. State, 174 N.E.3d 181, 190 n.2 (Ind. 2021)), and we will reverse “only where the decision is clearly against the logic and effect of the facts and circumstances,” Russell, 234 N.E.3d at 858 (quoting Smith v. State, 754 N.E.2d 502, 504 (Ind. 2001)). Tyler claims that the trial court abused its discretion by admitting (a) his admissions and (b) Lawrence's deposition testimony.

a. Admissions

[10] Tyler argues that the trial court should not have admitted the video of his interrogation. “Statements to police are admissible so long as they are voluntarily given.” Gibson v. State, 133 N.E.3d 673, 692 (Ind. 2019) (citing Pruitt v. State , 834 N.E.2d 90, 115 (Ind. 2005)). Tyler claims that his confession was not given voluntarily. “[T]he Indiana Constitution requires the state to prove ‘beyond a reasonable doubt that the defendant voluntarily waived his rights, and that the defendant's confession was voluntarily given.’ ”¹ Pruitt, 834 N.E.2d at 114–15 (quoting Miller v. State, 770 N.E.2d 763, 767 (Ind. 2002)). We have recently described our analysis for voluntary confessions as follows:

“A confession is voluntary if, in light of the totality of the circumstances, the confession is the product of a rational intellect and not the result of physical abuse, psychological intimidation, or deceptive interrogation tactics that have overcome the defendant's free will.” Shelby v. State, 986 N.E.2d 345, 365 (Ind. Ct. App. 2013), trans. denied. “The critical inquiry is whether the defendant's statements were induced by violence, threats, promises, or other improper influence.” Id. The trial court's determination of voluntariness “is reviewed in the same way as other sufficiency matters.” Clark v. State , 808 N.E.2d 1183, 1191 (Ind. 2004) (citing Griffith v. State , 788 N.E.2d 835, 842 (Ind. 2003)).

Graff v. State, 250 N.E.3d 497, 505 (Ind. Ct. App. 2025).

[11] Tyler claims that his statements were not voluntary because he was “tired, thirsty, and experiencing mental problems.” Appellant's Br. at 12. A defendant's mental health and physical condition are relevant factors in the voluntariness determination, see Wilkes v. State, 917 N.E.2d 675, 680 (Ind. 2009) (citing Miller, 770 N.E.2d at 767), but the mere presence of some impairment at the time of the confession is not sufficient to show a confession was involuntary, see Pruitt, 834 N.E.2d at 115–16. Those circumstances must be accompanied by some evidence of coercion to show that the defendant did not voluntarily confess. See id.

[12] There is no evidence that Detective Sinks coerced Tyler into admitting that he shot at Lawrence. On appeal, Tyler claims that the admissions were coerced because Detective Sinks allegedly ignored that Tyler had mental problems and that Tyler was hungry and thirsty. We cannot agree. While these are circumstances that should be considered when determining the voluntariness of a statement, the presence of these factors alone is insufficient to show the confession was involuntary. See Pruitt, 834 N.E.2d at 115–16 (citing Pettiford v. State, 619 N.E.2d 925, 928 (Ind. 1993)). Additionally, the mental problems that Tyler described were in relation to his prior involvement in a shooting and watching his brother die and not to his mental state during the interrogation. Tyler told Detective Sinks that he was “losing it,” Ex. 49R at 24:41–24:42, and had taken psych meds since seeing his brother die. Although Tyler claims that he had ongoing mental problems, he admitted that he had not been taking any psych meds “for a minute.” Id. at 33:10–33:11. We cannot say that Tyler's alleged mental state during the shooting affected the voluntariness of his confession that occurred the following day.

[13] Tyler also argues that Detective Sinks coerced him by refusing to give him water when he was thirsty. In fact, Tyler never asked for water. He accepted Detective Sinks's offer to bring him water. And, later Detective Sinks did provide water to Tyler. There was no promise to provide water conditioned on a confession. We are unpersuaded by Tyler's claim that Detective Sinks coerced him into giving a confession.

[14] Tyler also points us to the portion of the interrogation where Detective Sinks allegedly “begs, pleads, mentally challenges, and directs Tyler to disclose the location of the weapon so that a small child does not get injured discovering it.” Appellant's Br. at 16. Regardless of Tyler's characterization, this argument is of no moment because, at this point in the interrogation, Tyler had already admitted to shooting at Lawrence. We conclude that the circumstances support the trial court's conclusion that the statements were given voluntarily.

b. Lawrence's Deposition Testimony

[15] Tyler also argues that the trial court abused its discretion by admitting Lawrence's deposition testimony. Deposition testimony is admissible when “a party who had ․ an opportunity and similar motive to develop it by direct, cross-, or redirect examination.” Ind. Evidence Rule 804(b)(1)(B). Tyler claims that the deposition testimony was inadmissible because it violates the Confrontation Clause of the United States Constitution. “[T]he constitutional right of confrontation restricts the range of admissible hearsay by requiring (1) that the statements bear sufficient indicia of reliability and (2) that the prosecution either produce the declarant or demonstrate the unavailability of the declarant whose statement it wishes to use against the defendant.” Garner v. State, 777 N.E.2d 721, 724 (Ind. 2022) (citing Jackson v. State, 735 N.E.2d 1146, 1150 (Ind. 2000)); see also Crawford v. Washington, 541 U.S. 36, 68–69 (2004).

[16] Even assuming that the trial court erred by admitting Lawrence's deposition testimony, any error would be harmless. “An error is harmless when it results in no prejudice to the ‘substantial rights’ of a party.” Hall v. State, 177 N.E.3d 1183, 1197 (Ind. 2021) (quoting Durden v. State, 99 N.E.3d 645, 652 (Ind. 2018); see also Ind. Appellate Rule 66(A). In conducting our harmless error analysis, factors we consider are “the presence or absence of other, corroborating evidence on material points; whether the impermissibly admitted evidence was cumulative; the overall strength of the prosecution's case; the importance of the impermissible evidence in the prosecution's case; and the extent of cross-examination or questioning on the impermissibly admitted evidence.” Hall, 177 N.E.3d at 1197 (quoting Zanders v. State, 118 N.E.3d 736, 745–46 (Ind. 2019)).

Here, Lawrence's deposition testimony was cumulative of other evidence and was of little importance to the State's case. Lawrence's deposition echoed other testimony, describing the argument at Cambridge Estates that was followed by gunfire. More importantly, Lawrence's testimony was of minimal help to the State's case because he did not “have any idea” where the shots came from or who fired the gun. Tr. Vol. II at 167. Because Lawrence's testimony reiterated events that were already into evidence and did not identify Tyler, we conclude that any error in its admission was harmless.

[17] In sum, the trial court did not abuse its discretion by admitting Tyler's confession and any error in the admission of Lawrence's deposition testimony was harmless. We affirm the trial court on all issues raised.

[18] Affirmed.

FOOTNOTES

1.   We note that Tyler also mentions the standard for voluntariness under the United States Constitution, but he does not provide any argument or authority related to this standard. Tyler argues only the reasonable doubt standard under the Indiana Constitution.

Felix, Judge.

Judges Mathias and Foley concur. Mathias, J., and Foley, J., concur.