Snow v. StateAnnotate this Case
Defendant carried a handgun as she battered a law enforcement officer and resisted law enforcement. Defendant was not charged with a firearm-related offense, but nonetheless, the State introduced her gun into evidence at trial. Defendant was found guilty of felony battery against a public safety official and resisting law enforcement. Defendant challenged the gun’s admission at trial. The Supreme Court affirmed, holding (1) res gestate did not survive the adoption of Indiana’s Rules of Evidence in 1994; and (2) under the Rules of Evidence, the trial court did not abuse its discretion admitting Defendant’s gun into evidence because the gun was relevant to Defendant’s aggressiveness, and the danger of unfair prejudice did not substantially outweigh its probative value.