COA: Rapper’s brokered peace treaty irrelevant in murder case

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A rapper convicted as an accomplice in the murder of Indianapolis disc jockey Thomas Keys failed on appeal to show his brokering of a peace treaty between rival rap groups was wrongly excluded from evidence in his trial.

A jury convicted Carlton Hart of murder and Class B felony counts of criminal confinement and conspiracy to commit criminal confinement. Hart owned a recording studio where Keys was found shot to death in November 2012, and he also challenged the sufficiency of the evidence against him on appeal.

“Hart wanted to use the 'completeness doctrine' to introduce details of the peace treaty he had organized as a means of showing his peaceful character. However, the admitted portions of his police statements already contained his assertions that he was a peaceful, harmless person, Judge Rudolph R. Pyle III wrote for the Indiana Court of Appeals panel in Carlton Hart v. State of Indiana, 49A05-1404-CR-191.

“In addition, the peace treaty took place almost five months before the shooting in his studio," and there is no showing that Keys was a member of a rival group involved in the treaty. "Thus, details about the peace treaty are irrelevant and unnecessarily add details that are likely to confuse the issues.”

The jury “could have reasonably inferred that Hart aided, induced, or caused the resulting confinement … and murder of Keys,” the court held in affirming the sufficiency of the evidence.


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