Michael M. Medaris, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

Case Summary

[1] Michael M. Medaris was convicted of Level 1 felony neglect of a dependent resulting in catastrophic injury and found to be a habitual offender. He now appeals, arguing that the trial court erred in overruling his Batson challenge and in finding him to be a habitual offender. Finding no error, we affirm.

Facts and Procedural History

[2] On April 5, 2023, a five-month-old child was in Medaris's care when the child suffered significant injuries, including subdural hematomas, retinal hemorrhages, rib fractures, and lacerations of the liver and pancreas. The child survived but will likely never walk, talk, be aware of his environment, or eat by mouth.

[3] In June 2024, the State charged Medaris with Level 1 felony neglect of a dependent resulting in catastrophic injury and Level 3 felony neglect of a dependent resulting in serious bodily injury. The State also alleged that Medaris is a habitual offender based on the following felony convictions: (1) Class D felony receiving stolen auto parts (committed 2007/convicted 2008); (2) Class C felony sexual misconduct with a minor (committed 2009/convicted 2011); and (3) Level 6 felony domestic battery (committed 2017/convicted 2018). See Appellant's App. Vol. 2 p. 24.

[4] A jury trial was held in November 2025. During voir dire, the State used a peremptory strike to remove the only African American (Prospective Juror 1067) on the venire. Prospective Juror 1067, who was unmarried and had no children, stated that she conducted “mental health therapy online” for depression, anxiety, and ADHD and that she had clients every day. Tr. Vol. 3 pp. 85, 110. Upon further questioning, she said that none of her clients were “in crisis” so it “would be okay” for her to reschedule them during the week-plus that the trial was projected to last. Id. at 85. Medaris raised a Batson challenge to the strike, and the State responded:

There were several reasons, Judge. One, her work schedule. I don't think it raised [to the level of] a for cause strike, but she had clients that she had to see, and I thought that was going to distract her from being able to pay attention to the evidence. She also has no children. She's not married. I think those all play into the evidence in this case. It was not based on race, gender, age, or anything discriminatory. It was mainly based on her work schedule and I just didn't think—With those other clients that she was going to have to move around and the responsibility she had to those clients, I didn't think that she was going to be able to pay attention to the evidence and then give her full, undivided attention.

Id. at 118. Medaris highlighted that Prospective Juror 1067 said she “was willing to set aside those things and move forward and take the time necessary for the next eight or nine days.” Id. The trial court concluded “that the State of Indiana has provided a race-neutral explanation for why they removed the juror. I find that it is not a pretext for discrimination based off the answer provided by the State of Indiana, and will overrule the Batson challenge.” Id. at 118-19.

[5] After the first phase of trial, the jury found Medaris guilty of both neglect counts, and the trial court entered judgment of conviction on only the Level 1 felony count due to double-jeopardy concerns. Medaris then waived his right to a jury trial on the habitual-offender enhancement. The State presented certified records of Medaris's three prior felony convictions. See Exs. 27-29. The trial court found that Medaris is a habitual offender and sentenced him to 37 years for the Level 1 felony enhanced by 15 years for being a habitual offender, for a total of 52 years.

[6] Medaris now appeals.

Discussion and Decision

I. The trial court did not err in overruling Medaris's Batson challenge

[7] Medaris contends that the trial court erred in overruling his Batson challenge. The use of a peremptory challenge to strike a potential juror solely based on race violates the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. Batson v. Kentucky, 476 U.S. 79, 89 (1986). “Upon appellate review, a trial court's decision concerning whether a peremptory challenge is discriminatory is given great deference, and will be set aside only if found to be clearly erroneous.” Cartwright v. State, 962 N.E.2d 1217, 1221 (Ind. 2012).

[8] When a party raises a Batson challenge, the trial court must engage in a three-part test. Highler v. State, 854 N.E.2d 823, 826 (Ind. 2006). First, the court must determine “whether the defendant has made a prima facie showing that the prosecutor exercised a peremptory challenge on the basis of race.” Id. at 826-27. Striking the only minority venire member is sufficient to raise an inference of discrimination. See id. at 827.

[9] Second, “the burden shifts to the State to present a race-neutral explanation for striking the juror.” Id. “Unless a discriminatory intent is inherent in the prosecutor's explanation, the reason offered will be deemed race neutral.” Addison v. State, 962 N.E.2d 1202, 1209 (Ind. 2012) (quotation omitted). “Although the race-neutral reason must be more than a mere denial of improper motive, the reason need not be particularly persuasive, or even plausible.” Id. (quotation omitted).

[10] At the final step, the trial court evaluates the persuasiveness of the step-two justification. Id. at 1210. “It is then that implausible or fantastic justifications may (and probably will) be found to be pretexts for purposeful discrimination.” Id. (quotation omitted). In short, the issue is whether the court finds the prosecutor's race-neutral explanation credible. Id.

[11] Medaris acknowledges that the State provided a race-neutral explanation under the second step. Instead, he argues that the trial court impermissibly combined the second and third steps. He compares this case to Addison. There, the State used peremptory strikes on the only three African American prospective jurors, and the defendant lodged a Batson objection. The trial court concluded, “Well, I do think the State's articulated race neutral reasons for striking all three jurors, so I'm going to deny the Batson motion.” Id. at 1207. On appeal, our Supreme Court found that “by simply declaring, without more, that the State ‘articulated race neutral reasons for striking all three jurors,’ the trial court appears to have combined stages two and three of the Batson inquiry. This was incorrect.” Id. at 1210 (record citation omitted).

[12] This case is not like Addison. Here, after acknowledging that the State had “provided a race-neutral explanation,” the trial court went on to make an express credibility determination: “I find that it is not a pretext for discrimination based off the answer provided by the State of Indiana, and will overrule the Batson challenge.” A finding that the explanation is “not a pretext for discrimination” is the very determination that defines the third step. Unlike Addison, the court here did not stop at the facial race-neutrality of the reason; it proceeded to resolve the ultimate question of purposeful discrimination against Medaris. Because that determination turns substantially on credibility, it is entitled to great deference, and Medaris has not shown it to be clearly erroneous.

[13] Medaris makes a second argument that he didn't make below. That is, he argues that the peremptory strike was pretextual because some of the seated jurors shared the characteristics the State gave for striking Prospective Juror 1067. As Medaris recognizes, because he raises this issue for the first time on appeal, he must establish fundamental error. “An error is fundamental, and thus reviewable on appeal, if it made a fair trial impossible or constituted a clearly blatant violation of basic and elementary principles of due process presenting an undeniable and substantial potential for harm.” Durden v. State, 99 N.E.3d 645, 652 (Ind. 2018) (quotation omitted).

[14] Medaris again directs us to Addison. There, the defendant argued that the State's explanation for striking Turner, one of the African American prospective jurors, was pretextual because the voir dire record showed that non-minority prospective jurors gave the same or similar answers but were not struck. As here, the defendant argued fundamental error. Our Supreme Court found pretextual racial discrimination based on three reasons: (1) the State mischaracterized Turner's testimony when defending the strike, (2) the State failed to engage Turner in any meaningful voir dire on the reason it gave for striking him, and (3) a side-by-side comparison of Turner's and the seated jurors’ responses revealed that they were “strikingly similar.” Addison, 962 N.E.2d at 1215. The Court emphasized that, “[c]onsidered individually or in isolation, these factors likely would not be sufficient under our fundamental error standard of review to undermine the State's claim that its reason for striking Turner was race-neutral.” Id. at 1216. Only “taken collectively” did they compel a finding of pretext making a fair trial impossible. Id. at 1217.

[15] Here, Medaris identifies no mischaracterization, and the record reflects that the State questioned Prospective Juror 1067 about the very concern it invoked.¹ He is left with the comparative factor alone. Medaris notes that Prospective Jurors 168, 347, and 976 had concerns about work obligations but were not struck and that Prospective Juror 1041 was childless but also was not struck. Specifically, Prospective Juror 168 worked at Subaru and was worried about its jury-duty policy (he called Human Resources during a break and was no longer worried). Prospective Juror 347 was one of three mail carriers for the city of Delphi and said if the trial didn't last longer than anticipated, she could miss work, and mail would still get delivered. And Prospective Juror 976 explained that she had just been assigned a project the day before, that it would be waiting for her when she returned, and that it wouldn't distract her. The State's main concern was that Prospective Juror 1067's responsibility to reschedule multiple ongoing counseling clients would distract her from the evidence—not the secondary observations that she was unmarried and childless. Measured against that concern, none of the cited jurors faced the recurring client obligations the State identified, so its reason does not apply equally to them.

[16] In any event, as the State points out, Medaris hasn't identified any similarly situated non-minority jurors who were unmarried, childless, and had a job that would require rescheduling multiple clients if they were selected for jury duty. See Appellee's Br. pp. 15-16. Accordingly, this claim fails. See Davis v. State, 258 N.E.3d 999, 1008 (Ind. Ct. App. 2025) (“After side-by-side comparison, unlike in Addison, we cannot say that Potential Juror Number 93's voir dire responses were strikingly similar to responses given by the unchallenged jurors such that the same rationale offered by the State to remove [Potential Juror Number 93] applied equally to [Potential Jurors 3 and 95].” (quotations omitted)), trans. denied. Medaris has not met his burden of establishing fundamental error.

II. The trial court did not err in finding Medaris to be a habitual offender

[17] Medaris next contends that the trial court erred in finding him to be a habitual offender because the State did not prove the date he committed the current offense (neglect) during the habitual-offender phase. To find Medaris a habitual offender, the State was required to establish, among other things, the date he committed the current offense so that the trier of fact could determine the proper sequencing under Indiana Code section 35-50-2-8(f). Medaris argues that because he waived his right to a jury trial on the habitual-offender enhancement and the enhancement was tried to the judge and not the jury, the State was required to prove the date he committed the current offense to the judge.

[18] But the authorities Medaris relies on do not support reversal because they address a materially different situation. Those cases involve a successor jury empaneled solely for the habitual-offender phase—a jury unfamiliar with the evidence from the guilt phase. In that circumstance, the State must establish “the date of the current underlying felony” so that the jury can “make a proper determination of sequence.” Warren v. State, 769 N.E.2d 170, 171 (Ind. 2002); see also Wade v. State, 718 N.E.2d 1162, 1170 (Ind. Ct. App. 1999) (noting that “evidence of the date of commission of the felony for which enhancement has been sought is required if a different jury hears the habitual part of the trial”), reh'g denied, trans. denied. Medaris acknowledges that he could not “locate guidance on the requisite amount of proof when the trier of fact changes from a jury to a judge at each stage of the bifurcated proceeding.” Appellant's Br. p. 26.

[19] The rationale from the cases Medaris cites is absent here because the judge presided over the entire trial. Although the State still had to establish the date of the current offense, the record did so here. During the guilt phase, the April 5, 2023 offense date was established repeatedly. The date was also included in the charging information and the jury instructions. See Wade, 718 N.E.2d at 1170 (“The date upon which an offense may have been committed may be found in the State's charging instruments, in transcripts of guilty plea proceedings, within the evidence admitted at trial and in the jury instructions given by the court.”). Because the date of the current offense was already in the record before the judge who had presided over the guilt phase, the concern that drove Warren—a successor jury unfamiliar with the guilt-phase evidence—was absent, and the State was not required to reintroduce that date during the habitual-offender phase. Because the evidence established the required sequence, the trial court did not err in finding Medaris to be a habitual offender.

[20] Affirmed.

FOOTNOTES

1.   Medaris acknowledges that the State questioned Prospective Juror 1067 about her work obligations. However, he claims that the State didn't question Prospective Juror 1067 as thoroughly as it did the other prospective jurors on other matters. The State disputes this characterization, claiming that it questioned Prospective Juror 1067 “similarly to other prospective jurors.” Appellee's Br. p. 16. In any event, “disparate questioning ․ alone does not constitute a Batson violation” and “may reflect ordinary race-neutral considerations.” Flowers v. Mississippi, 588 U.S. 284, 310 (2019).

Vaidik, Judge.

Altice, J., and Foley, J., concur.