The Indiana Court of Appeals has affirmed the conviction of Brady McDaniel on charges of obstruction of justice and operating a vehicle while intoxicated, despite a brief mention of his conditional license during the trial. The court found that the trial judge did not abuse his discretion by denying McDaniel’s motion for a mistrial.
The Incident
[3] On February 1, 2024, Captain Tyler Irwin of the Elwood Police Department observed McDaniel speeding and driving erratically on State Road 37 in Madison County, Indiana. Captain Irwin pulled McDaniel over and, upon speaking with him, detected the smell of alcohol, observed redness in his eyes, and noted slurred speech. McDaniel refused to participate in a field sobriety test. Law enforcement officers found an open beer bottle and a bag of suspected marijuana in his vehicle. Although Captain Irwin secured a warrant for a blood draw, McDaniel refused to allow his blood to be drawn.
The Charges and Pre-Trial Maneuvers
[4] McDaniel was charged with several offenses, including obstruction of justice, operating a vehicle while intoxicated, violation of an ignition interlock order, possession of marijuana, violation of driving conditions, and as a habitual vehicle substance offender. However, the prosecution dropped the possession of marijuana charge before the trial. On the morning of the trial, McDaniel pleaded guilty to violating driving conditions and the ignition interlock order. He also made an oral motion to exclude any mention of his conditional license or the need for an ignition interlock. The trial court granted this motion.
The Contested Evidence
[5] During the trial, the prosecution presented a partially redacted portion of Captain Irwin’s body camera footage. In the footage, Captain Irwin asked McDaniel which court had issued his conditional license. McDaniel immediately objected and requested a hearing outside the jury’s presence. The trial court gave a general admonishment to the jury and released them for lunch before the hearing.
Motion for Mistrial and the Court’s Ruling
[6] During the hearing, McDaniel requested a mistrial, arguing that the mention of the conditional license was too prejudicial, as a conditional license “is not a reward for good behavior.” The trial court agreed that the reference was problematic but ultimately denied the mistrial because it determined that the single reference did not pose a significant risk that would require a mistrial. Upon the jury’s return from lunch, the trial court gave a specific admonishment to the jury, instructing them to disregard the reference to McDaniel’s license status.
The Verdict and Appeal
[7] Following the first phase of the trial, the jury found McDaniel guilty of obstruction of justice and operating a vehicle while intoxicated. McDaniel admitted to being a habitual vehicle substance offender and was sentenced to eight years, with six years of incarceration and two years suspended to probation. McDaniel appealed, arguing that the trial court abused its discretion by denying his motion for a mistrial.
The Court of Appeals’ Decision
[8, 9] The Court of Appeals reviewed the trial court’s decision, acknowledging that granting or denying a mistrial is within the trial court’s discretion. The appellate court emphasized that to succeed in an appeal based on a denied mistrial motion, McDaniel had to prove the mentioned conduct was so prejudicial and inflammatory that it put him in grave peril, necessitating a mistrial. The court also noted that a timely and accurate admonishment generally cures any error and that the jury is presumed to follow the court’s instructions.
Arguments and the Court’s Reasoning
[10, 11] McDaniel argued that the admonishment was untimely and that the reference to his conditional license placed him in grave peril. The Court of Appeals disagreed with both arguments. First, the court found the admonishment to be timely. The reference to the conditional license was brief and isolated. After the improper reference, the trial court held a hearing outside the jury’s presence and allowed McDaniel to provide input on the content of the admonishment. The trial court then gave a specific admonishment immediately after the jury returned from lunch. The court presumed the jury followed the trial court’s instructions.
[12] Second, the Court of Appeals found that McDaniel had not demonstrated that the isolated reference to his conditional license placed him in grave peril. The court emphasized that the standard for grave peril is whether the jury was improperly persuaded by the evidence, not simply whether the evidence was admitted inappropriately. The jury convicted McDaniel of obstruction of justice and operating a vehicle while intoxicated, and the court found that there was ample evidence to support those convictions, which did not require the jury to determine that he was driving on a conditional license. The court also noted that the term “conditional license” was not defined, and it was unlikely that a layperson would understand its meaning after a single inquiry.
Conclusion
[13] The Court of Appeals affirmed the trial court’s decision, concluding that the trial court did not abuse its discretion in denying the motion for a mistrial.