Indiana Supreme Court justices affirmed a man’s two murder convictions, finding his Miranda rights were not violated and that his sentence was appropriate. However, the high court remanded for a more specific sentencing statement as required.
Kevin Shuler pleaded guilty to the murder of Asenath Arnold and to felony murder for the death of Gary Henderson at the hands of his accomplice Austin Scott. Arnold, a mostly bedridden 57-year-old woman, was found dead in her home in 2013, along with Henderson, who slept in a separate room upstairs.
After the arrest of both Shuler and Scott at a separate location for firing shots in a neighborhood, Scott stated under his Miranda rights that he “killed a man last night” and that Schuler killed someone as well.
Schuler ultimately was sentenced to life without parole and a consecutive term of 65 years for convictions of murder and felony murder. On appeal, Schuler argued that his Miranda rights were violated, that there was insufficient evidence to prove he intentionally killed Arnold, and that his sentence was inappropriate.
The high court affirmed the trial court’s rulings on all three of Shuler’s claims, finding his Miranda rights were not violated and that his statement was not an unambiguous request for counsel. It then found that there was sufficient evidence to prove he intentionally killed Arnold by the manner of which he used the weapon to strike her in the head more than once.
Lastly, it confirmed that his sentence of life without parole was not inappropriate regardless of his age at the time of the murder, finding that “the law treats eighteen-year olds as adults.”
Justices decided differently on Shuler’s fourth claim, however, finding that the trial court’s sentencing statement did not comply with the dictates of Harrison v. State, 644 N.E.2d 1243, 1262 (Ind. 1995). Specifically, it found that although the trial court identified the aggravating circumstance of an intentional killing during the commission of a robbery, it referenced “other aggravating circumstances,” that were unidentifiable.
The high court also found it “hard to assess how the [trial] court balanced the factors without specific identification of any mitigating factors” and that the trial court’s statements implied that it came to the personal conclusion that the sentence was appropriate.“We therefore remand this matter to the trial court for a clearer sentencing statement that complies with the dictates of Harrison,” Justice Steven David wrote for the court in Kevin Andrew Schuler v. State of Indiana, 31S00-1703-LW-134.