Pratt v. State

Summary

The Indiana Supreme Court affirmed Ryan Pratt's convictions for murder, battery, and neglect of a dependent arising from the fatal blunt-force trauma inflicted on his eleven-month-old son. The court held that circumstantial evidence, including Pratt's exclusive presence with the child, the timing and pattern of the injuries, and the apnea-monitor readings, was sufficient to support the murder conviction. The court also rejected or waived related arguments concerning the source of the injuries, the preservation of potentially useful evidence, and the knowing mental state.

Holdings

1. The evidence was sufficient to support Pratt's murder conviction because the circumstantial evidence and reasonable inferences permitted a reasonable jury to find beyond a reasonable doubt that Pratt caused Dylan's fatal injuries.
2. The court did not separately address the sufficiency of the battery conviction because the trial court merged that conviction into the murder conviction.
3. Pratt did not establish a due-process violation based on the State's failure to preserve the telephone because the telephone was merely potentially useful evidence and he did not show bad faith.

Questions Presented

1. Whether sufficient evidence supported Pratt's murder conviction when no eyewitness testified that he struck Dylan.
2. Whether sufficient evidence supported the merged battery conviction.
3. Whether the State's failure to preserve the telephone for fingerprint or tissue analysis violated due process.

Disposition

affirmed