Summer Snow v. State of Indiana

On Petition to Transfer from the Indiana Court of Appeals, No. 45A03-1605-CR-1175

Rush, Chief Justice.

Every crime has a story. But when that story is told at trial, each part must be admissible under Indiana’s Rules of Evidence—simply being part of the story is not enough. We thus reiterate today our holding from over twenty years ago: res gestae—the common-law doctrine that made evidence admissible when it was part of a crime’s story—is no more.

Here, Summer Snow carried a handgun as she battered Officer Terry Peck and resisted law enforcement. Though she was not charged with a firearm-related…