Benefield v. State’s Empirical Analysis

Citation profile

6 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Final Instruction 6 impermissibly suggested to the jury that it could convict Benefield upon finding merely a “reckless” state of mind, when the forgery statute required that the making uttering or possession of the written instrument in question be done with the “intent to defraud.” Ind.Code § 35-43-5-2(b). A merely reckless state of mind is simply not compatible with a specific intent to defraud. To the extent that Final Instruction 6 suggests that a person recklessly making a representation may have the intent to defraud, we conclude that it is not a proper statement of the law. [[Image here]] [T]he instruction’s misstatement of the mens rea, [ ]does not rise to the level of fundamental error. In some cases, a jury instruction that misstates the mens rea amounts to fundamental error. See, e.g., Greer v. State, 643 N.E.2d 324, 327 (Ind.1994) (concluding that instruction that a defendant could “knowingly” commit attempted murder was fundamental error). Such an error can be cured, however, where the jury was otherwise sufficiently informed of the proper mens rea. Id. at 326-27. When determining whether a defendant suffered a due process violation based on an incorrect jury instruction, we look not to the erroneous instruction in isolation, but in the context of all relevant information given to the jury, including closing argument, and other instructions[.] There is no resulting due process violation where all such information, considered as a whole, does not mislead the jury”

   2 later decisions quote this exact passage
   e.g. Christapher Batchelor v. State of Indiana · Benefield v. State

2. “On March 28, 2005, Benefield applied for a health-care provider position with Regency Place in Greenwood and interviewed with Sabra Stark. Specifically, Benefield applied for a position as a Qualified Medication Aide (“QMA”), for which one needs certification from the Indiana Department of Health. To that end, Benefield produced a document that appeared to be an “Aide Registry [Letter]” issued by the Department of Health [on January 26, 2005]. [State’s Ex. 8.] Although the document indicated that Benefield was certified as a QMA, Stark noticed that both the QMA certification number and QMA expiration date listed on the document appeared to be in a typeface inconsistent with the rest of the document. After the interview, Stark called an automated telephone service to verify Benefield’s certifications, only to learn that Benefield was not certified as a QMA. In fact, neither the QMA certification number nor the expiration date listed on the “Aide Registry [Letter]” were valid. Moreover, the Department of Health does not issue corrected “Aide Registry” letters with the corrections in a different typeface, instead preparing new documents when information has changed. On September 2, 2005, the State charged Benefield with Class C felony forgery and with being an habitual offender. Before Benefield’s jury trial on August 8, 2007, both parties stipulated to the admissibility of several exhibits, including Aide Registry letters from the Department of Health dated May 13, 2005, and Au”

   1 later decision quote this exact passage
   e.g. Benefield v. State