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Keywords

appealtrialjury instructions

trialdue processjury instructions

Related Cases

McKinley v. State, 45 N.E.3d 25

Facts

On May 21, 2014, Jermaine McKinley was arrested by officers of the Indianapolis Metropolitan Police Department. During a search incident to his arrest, officers found five small baggies of suspected cocaine and $720 on his person. After being read his Miranda rights, McKinley admitted that the baggies contained cocaine and expressed a desire to dispose of the drugs. Forensic testing confirmed that he possessed 5.233 grams of cocaine, leading to charges of dealing in cocaine and possession of cocaine.

During a search incident to arrest, Officer Burton discovered five small baggies of suspected cocaine and $720 on McKinley's person.

Issue

Did the trial court properly instruct the jury regarding the requisite mental state for the offense of possession of cocaine with intent to deliver?

McKinley contends the jury instructions misstated the requisite mental state for possession of cocaine with intent to deliver.

Rule

The court applied the principle that specific intent is not required for every element of the offense of dealing in cocaine, and that jury instructions must be evaluated in the context of the entire trial.

The fundamental error exception is extremely narrow and applies only when an error constitutes a blatant violation of basic principles of due process.

Analysis

The court analyzed the jury instructions as a whole, noting that the instructions clearly outlined the elements of the offense, including the requirement of intent to deliver. The court found that the inclusion of the term 'knowingly' did not mislead the jury regarding the necessary mental state, as the focus of the trial was on McKinley's intent to deliver the cocaine. The court concluded that the jury was adequately informed of the law applicable to the facts of the case.

Reading the jury instructions as a whole and in the context of all the information given to the jury, we cannot say the instructions were misleading regarding the requirement of intent to deliver.

Conclusion

The Court of Appeals affirmed McKinley's conviction for dealing in cocaine, concluding that the trial court did not commit fundamental error in its jury instructions.

The trial court did not commit fundamental error when it instructed the jury that McKinley could be convicted under Indiana Code section 35–48–4–1(a)(2)(C) for 'knowingly' possessing cocaine with intent to deliver.

Who won?

The State prevailed in the case, as the court found that the jury instructions were sufficient and did not constitute fundamental error.

The State contends the 'knowingly or intentionally' that appears in Indiana Code section 35–48–4–1(a)(1) applies to subsection (a)(2) as well.

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Wiggins v. Smith, 539 U.S. 510, 123 S.Ct. 2527, 156 L.Ed.2d 471, 71 USLW 4560, 03 Cal. Daily Op. Serv. 5586, 2003 Daily Journal D.A.R. 7015, 16 Fla. L. Weekly Fed. S 459