Means v. StateAnnotate this Case
In this interlocutory appeal, the Supreme Court affirmed the judgment of the criminal court entering an order in limine excluding from evidence the juvenile court's order in a child in need of services (CHINS) proceedings, holding that the trial court did not abuse its discretion by excluding the CHINS order.
The Department of Child Services (DCS) filed a petition alleging that E.H., who was less than fourteen years old, was a CHINS. The juvenile court denied the petition after a fact-finding hearing. After further investigation, the State charged Defendant with Level 5 felony battery resulting in bodily injury to E.H. When Defendant sought to introduce at trial the CHINS order as evidence that someone else likely injured E.H. the State filed a motion to exclude that evidence in limine. The trial court granted the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by excluding the CHINS order under the circumstances of this case.