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Ward v. State

Citations: 519 N.E.2d 561; 1988 Ind. LEXIS 84; 1988 WL 13954Docket: 1284S507

Court: Indiana Supreme Court; February 24, 1988; Indiana; State Supreme Court

Narrative Opinion Summary

In this case, the defendant was convicted of murder and designated as an habitual offender, resulting in a 70-year enhanced sentence. The conviction followed his confession to murdering a prostitute, whom he struck and strangled after she attempted to rob him. The defendant contested the trial court's decision for not instructing the jury on voluntary intoxication, claiming his drug and alcohol use impaired his intent. However, this argument was waived as it was not raised during the trial or in post-trial motions. The court found no fundamental error, as the defendant's actions demonstrated intent and coordination. Additionally, the defendant's request for instructions on voluntary manslaughter, based on 'sudden heat', was denied due to insufficient evidence and improper submission, further waiving this claim. The appellate court affirmed the trial court's decisions, concurring unanimously in the outcome.

Legal Issues Addressed

Enhanced Sentencing for Habitual Offenders

Application: The defendant's status as an habitual offender supported the imposition of a 70-year enhanced sentence.

Reasoning: William Ward was convicted of murder and found to be an habitual offender, resulting in a 70-year enhanced sentence.

Fundamental Error Doctrine

Application: The court held that the absence of a jury instruction on voluntary intoxication did not constitute fundamental error, as there was no blatant violation of basic principles.

Reasoning: The court noted that fundamental error requires a blatant violation of basic principles, which was not present in this case.

Voluntary Manslaughter Instructions

Application: The court rejected the defendant's request for instructions on voluntary manslaughter due to lack of evidence supporting 'sudden heat' and improper submission of instructions.

Reasoning: The court found that Ward did not present evidence to support the existence of sudden heat during the trial and that his instructions were improperly submitted, further waiving his claim.

Waiver of Defense Arguments

Application: The defendant waived his argument for a jury instruction on voluntary intoxication by not requesting it during the trial or raising it in his motion to correct errors.

Reasoning: However, he did not request such an instruction during the trial and did not raise this issue in his motion to correct errors, leading the court to rule that he waived this argument.