chain of custody rule in Indiana

47 Indiana opinions name it 2 courts 1972–2023 1 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

Case	Followed	Cited
Bell v. Stategreen ind · 1993 · cited in 4 Indiana opinions naming this issue, 1995–2012 2 sentences 2012“Under the chain of custody doctrine, an adequate foundation is laid when the continuous whereabouts of an exhibit is shown from the time it came into the possession of the police.” Cockrell v. State, 743 N.E.2d 799, 808 (Ind. Ct. App. 2001) (citing Bell v. State, 610 N.E.2d 229, 232-33 (Ind. 1993)). 2001Bell v. State *809 (1993) Ind., 610 N.E.2d 229, 232-33 .	2	4
Graham v. Stategreen ind · 1970 · cited in 9 Indiana opinions naming this issue, 1973–1987 2 sentences 1982The chain of custody doctrine was established in Graham v. State (1970) 253 Ind. 525 , 255 N.E.2d 652 . 1982The chain of custody doctrine was established in Graham v. State (1970) 253 Ind. 525 , 255 N.E.2d 652 .	1	9
Arnold v. Stategreen ind · 1982 · cited in 2 Indiana opinions naming this issue, 1991–2023 2 sentences 2023Arnold v. State, 436 N.E.2d 288, 291 (Ind. 1982); see also Cliver v. State, 666 N.E.2d 59, 63 (Ind. 1996) (“The purpose of the chain of custody requirement is to demonstrate the continuous whereabouts of an exhibit from the time it comes into the possession of the police until the time it is presented at trial.”). 1991Arnold v. State (1982), Ind., 436 N.E.2d 288 at 291 .	1	2
Morse v. Stategreen ind · 1992 · cited in 2 Indiana opinions naming this issue, 1994–2019 2 sentences 2019The State points out that the purpose of the chain of custody rule is to “ensure that during the time the evidence is in the possession of the law enforcement authorities, there is not a substitution or alteration of the evidence.” Morse v. State, 593 N.E.2d 194, 197 (Ind. 1992). [13] We have held that “[a] properly conducted controlled buy will permit an inference the defendant had prior possession of a controlled substance.” Watson v. State, 839 N.E.2d 1291, 1293 (Ind. Ct. App. 2005). 1994Morse v. State (1992), Ind., 593 N.E.2d 194, 197 .	1	2
Cliver v. Stategreen ind · 1996 · cited in 1 Indiana opinions naming this issue, 2023–2023 1 sentence 2023Arnold v. State, 436 N.E.2d 288, 291 (Ind. 1982); see also Cliver v. State, 666 N.E.2d 59, 63 (Ind. 1996) (“The purpose of the chain of custody requirement is to demonstrate the continuous whereabouts of an exhibit from the time it comes into the possession of the police until the time it is presented at trial.”).	1	1
Watson v. Stategreen indctapp · 2005 · cited in 1 Indiana opinions naming this issue, 2019–2019 2 sentences 2019McMickle relies on Watson, 839 N.E.2d at 1293 , which held: “Because the CI was not searched prior to the buy and the CI did not testify about receiving the cocaine from Watson, we must agree with Watson that no reasonable fact-finder, based on this evidence alone, could have found beyond a reasonable doubt he originally possessed the cocaine found on the CI after the buy.” [14] Watson is distinguishable from this case. 2019The State points out that the purpose of the chain of custody rule is to “ensure that during the time the evidence is in the possession of the law enforcement authorities, there is not a substitution or alteration of the evidence.” Morse v. State, 593 N.E.2d 194, 197 (Ind. 1992). [13] We have held that “[a] properly conducted controlled buy will permit an inference the defendant had prior possession of a controlled substance.” Watson v. State, 839 N.E.2d 1291, 1293 (Ind. Ct. App. 2005).	1	1
Treadway v. Stategreen ind · 2010 · cited in 1 Indiana opinions naming this issue, 2014–2014 1 sentence 2014Birk did not object on this ground at trial.4 “Failure to object at trial waives the issue for review unless fundamental error occurred.” Treadway v. State, 924 N.E.2d 621, 633 (Ind. 2010).	1	1
Cockrell v. Stategreen indctapp · 2001 · cited in 1 Indiana opinions naming this issue, 2012–2012 1 sentence 2012“Under the chain of custody doctrine, an adequate foundation is laid when the continuous whereabouts of an exhibit is shown from the time it came into the possession of the police.” Cockrell v. State, 743 N.E.2d 799, 808 (Ind. Ct. App. 2001) (citing Bell v. State, 610 N.E.2d 229, 232-33 (Ind. 1993)).	1	1
Dickerson v. Stategreen ind · 1986 · cited in 1 Indiana opinions naming this issue, 1989–1989 1 sentence 1989See Dickerson v. State (1986), Ind., 488 N.E.2d 346, 348 ; Johnson v. State (1983), Ind., 447 N.E.2d 1072, 1074 .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (32)

Case	Cited	Years
Woodard v. State neutral ind · 1977 2 sentences 1990Woodard v. State, (1977) 267 Ind. 19, 24 , 866 N.E.2d 1160 , 1164. 1990Woodard v. State, (1977) 267 Ind. 19, 24 , 366 N.E.2d 1160, 1164 .	5	1982–1990
Wray v. State green ind · 1989 2 sentences 1993Wray v. State (1989), Ind., 547 N.E.2d 1062 . 1993Id.	3	1991–1993
Wolfe v. State green ind · 1978 2 sentences 1988Wolfe v. State (1978), 270 Ind. 81 , 383 N.E.2d 317 . 1979In Wolfe v. State, (1978) Ind., 383 N.E.2d 317, 318 , our Supreme Court said: “The purpose of the chain of custody rule is the avoidance of any claims of substitution, tampering or mistake. .	3	1979–1988
Coleman v. State green ind · 1975 2 sentences 1982However, the chain of custody rule applies with diminishing strictness as the exhibits concerned become decreasingly susceptible to alteration, tampering or substitution.” Coleman v. State, (1975) 264 Ind. 64, 69 , 339 N.E.2d 51 . 1982However, the chain of custody rule applies with diminishing strictness as the exhibits concerned become decreasingly susceptible to alteration, tampering or substitution.” Coleman v. State, (1975) 264 Ind. 64, 69 , 339 N.E.2d 51 .	3	1978–1982
Wilson v. State green ind · 1975 2 sentences 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975). 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975).	2	1978–1986
Johnson v. State green ind · 1977 2 sentences 1980Johnson v. State, (1977) 267 Ind. 415 , 370 N.E.2d 892 . 1980Johnson v. State, (1977) 267 Ind. 415 , 370 N.E.2d 892 .	2	1978–1980
Martin v. State green ind · 1974 2 sentences 1974More recently, in Martin v. State (1974), 262 Ind. 232 , 314 N.E.2d 60 , the court stated the chain of custody rule as follows: “The chain of custody rule in Indiana requires that before an exhibit may be introduced against a defendant at trial the State must establish a link between the defendant and the exhibit and also establish the whereabouts of the exhibit from the time of the seizure until its introduction at trial. 1974More recently, in Martin v. State (1974), 262 Ind. 232 , 314 N.E.2d 60 , the court stated the chain of custody rule as follows: “The chain of custody rule in Indiana requires that before an exhibit may be introduced against a defendant at trial the State must establish a link between the defendant and the exhibit and also establish the whereabouts of the exhibit from the time of the seizure until its introduction at trial.	2	1974–1977
Baker v. Wagers green indctapp · 1984 2 sentences 1995The derivation of the exception before the adoption of the Indiana Rules of Evidence is carefully traced in Baker v. Wagers (1984), Ind.App., 472 N.E.2d 218 . . 1995We do not read Fendley as establishing a chain of custody requirement. [5] The derivation of the exception before the adoption of the Indiana Rules of Evidence is carefully traced in Baker v. Wagers (1984), Ind. App., 472 N.E.2d 218 . [6] Evid.R. 703 provides: The facts or data in the particular case upon which an expert bases an opinion or inference may be those perceived by or made known to the expert at or before the hearing.	1	1995–1995
Hughett v. State green ind · 1990 2 sentences 1993Hughett v. State (1990), Ind., 557 N.E.2d 1015, 1019 . 1993Hughett v. State (1990), Ind., 557 N.E.2d 1015, 1019 .	1	1993–1993
Woods v. State green ind · 1989 2 sentences 1992Woods v. State (1989), Ind., 547 N.E.2d 772 , cert. denied, — U.S. -, 111 S.Ct. 2911 , 115 L.Ed.2d 1074 ; Delatorre v. State (1989), Ind., 544 N.E.2d 1379 . 1992Woods v. State (1989), Ind., 547 N.E.2d 772 , cert. denied, ___ U.S. ___, 111 S.Ct. 2911 , 115 L.Ed.2d 1074 ; Delatorre v. State (1989), Ind., 544 N.E.2d 1379 .	1	1992–1992
Delatorre v. State neutral ind · 1989 2 sentences 1992Woods v. State (1989), Ind., 547 N.E.2d 772 , cert. denied, — U.S. -, 111 S.Ct. 2911 , 115 L.Ed.2d 1074 ; Delatorre v. State (1989), Ind., 544 N.E.2d 1379 . 1992Woods v. State (1989), Ind., 547 N.E.2d 772 , cert. denied, ___ U.S. ___, 111 S.Ct. 2911 , 115 L.Ed.2d 1074 ; Delatorre v. State (1989), Ind., 544 N.E.2d 1379 .	1	1992–1992
Brafford v. State green ind · 1987 1 sentence 1990Brafford v. State (1987), Ind., 516 N.E.2d 45 .	1	1990–1990
McAnalley v. State green ind · 1987 1 sentence 1989McAnalley v. State (1987), Ind., 514 N.E.2d 831 .	1	1989–1989
Johnson v. State green ind · 1983 1 sentence 1989See Dickerson v. State (1986), Ind., 488 N.E.2d 346, 348 ; Johnson v. State (1983), Ind., 447 N.E.2d 1072, 1074 .	1	1989–1989
Duncan v. State green ind · 1980 1 sentence 1987Duncan v. State (1980), Ind., 409 N.E.2d 597 .	1	1987–1987
Russell v. State green ind · 1986 1 sentence 1987Graham v. State (1970), 253 Ind. 525 , 255 N.E.2d 652 ; Russell v. State (1986), Ind., 489 N.E.2d 955 ; Lilly v. State (1985), Ind., 482 N.E.2d 457 .	1	1987–1987
Lilly v. State neutral ind · 1985 1 sentence 1987Graham v. State (1970), 253 Ind. 525 , 255 N.E.2d 652 ; Russell v. State (1986), Ind., 489 N.E.2d 955 ; Lilly v. State (1985), Ind., 482 N.E.2d 457 .	1	1987–1987
Holt v. State green ind · 1980 2 sentences 1987The purpose of the chain of custody requirement is to provide reasonable assurance that the exhibit has not been substituted or tampered with, Holt v. State (1980), 272 Ind. 544 , 400 N.E.2d 130 . 1987The purpose of the chain of custody requirement is to provide reasonable assurance that the exhibit has not been substituted or tampered with, Holt v. State (1980), 272 Ind. 544 , 400 N.E.2d 130 .	1	1987–1987
Parks v. State green ind · 1979 2 sentences 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975). 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975).	1	1986–1986
Pollard v. State green ind · 1979 2 sentences 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975). 1986Parks v. State (1979), 270 Ind. 689, 694 , 389 N.E.2d 286, 290 ; Pollard v. State (1979), 270 Ind. 599, 611 , 388 N.E.2d 496, 505 ; Wilson v. State (1975), 263 Ind. 469, 481 , 333 N.E.2d 755, 762 , reh. denied (1975).	1	1986–1986
Armand v. State green ind · 1985 1 sentence 1985If the offered item possesses characteristics which are fairly unique and readily identifiable, and if the substance of which the item is composed is relatively impervious to change, the trial court is viewed as having broad discretion to admit it merely upon the basis of testimony that the item is the one in question and is in a substantially unchanged condition." (Citations omitted.) Armand v. State, (1985) Ind., 474 N.E.2d 1002, 1005 , quoting Dier v. State, (1982) Ind., 442 N.E.2d 1043, 1046 .	1	1985–1985
Dier v. State green ind · 1982	1	1985–1985
Kelly v. State neutral ind · 1975	1	1976–1976
Traylor v. State neutral indctapp · 1975	1	1976–1976
Kelley v. State neutral indctapp · 1974	1	1976–1976
Hopper v. State green indctapp · 1974	1	1975–1975
Mayes v. State green indctapp · 1974	1	1975–1975
Gibson v. State green indctapp · 1973	1	1975–1975
Bonds v. State neutral indctapp · 1973	1	1975–1975
Fletcher v. State green ind · 1970	1	1975–1975
Pullins v. State green ind · 1970	1	1975–1975
Guthrie v. State green ind · 1970	1	1972–1972

Statutes the citing opinions construe

IN § Ind. Code § 35-42-5-1 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IN 47 (1972–2023) TN 42 (1999–2026) VA 34 (1984–2025) GA 28 (1986–2021) IL 22 (1991–2023) LA 20 (1988–2014) CA 13 (2001–2026) OK 13 (1984–2010) SC 13 (2004–2025) AL 9 (1994–2014) TX 8 (2010–2026) MO 7 (1975–1992) MN 6 (1976–2016) WA 5 (1996–2024) ME 5 (1976–2018) NY 5 (1977–2023) ND 4 (1979–2005) AR 4 (1995–2022) DE 4 (1987–2020) CO 4 (1999–2026) DC 3 (1994–2016) PA 3 (2008–2023) MD 2 (1989–2024) VI 2 (2013–2026) CT 2 (1989–2021) WV 2 (1977–1987)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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