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March 13, 2026 Get Citation Alerts Download PDF Add Note

Bruce Mendenhall v. State of Indiana

Indiana Court of Appeals

• Citations: None known
• Docket Number: 25A-CR-00775
• Panel: Cale J. Bradford, Nancy H. Vaidik
• Judges: Bradford, Vaidik, Altice

• Disposition: Affirmed

• Opinion

• Authorities (16)

• Cited By (0)

• Summaries (0)

• Similar Cases (12.7K)

• PDF

Disposition

Affirmed

Combined Opinion

                        by [Nancy H. Vaidik](https://www.courtlistener.com/person/7282/nancy-h-vaidik/)

IN THE

Court of Appeals of Indiana
Bruce Mendenhall, FILED
Mar 13 2026, 8:31 am
Appellant-Defendant
CLERK
Indiana Supreme Court
Court of Appeals
and Tax Court
v.

State of Indiana,
Appellee-Plaintiff

March 12, 2026
Court of Appeals Case No.
25A-CR-775
Appeal from the Marion Superior Court
The Honorable Angela Dow Davis, Judge
Trial Court Cause No.
49D27-0804-MR-77498

Opinion by Judge Vaidik
Judges Bradford and Altice concur.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 1 of 18
Case Summary
[1] In 2007, Bruce Mendenhall was stopped by a Tennessee police officer at a truck

stop in Nashville and consented to a search of his semi-truck. The officer found

bloody women’s clothes and transported Mendenhall to a police station, where

he admitted that he had picked up a woman at an Indianapolis truck stop the

night before and that she had been shot in the head with his rifle. Mendenhall

also admitted that he had driven south on I-65 from Indianapolis to Nashville.

The woman was eventually identified as Carma Purpura from Indianapolis. In

2008, the State of Indiana charged Mendenhall with Purpura’s murder in

Marion County. The case was still pending when, several years later, Purpura’s

remains were found in southern Kentucky near I-65.

[2] The State paused its prosecution of Mendenhall in Indiana while he was tried in

Tennessee for the deaths of two additional women and sentenced to two life

sentences. In 2021, the State resumed its prosecution, and Mendenhall was

convicted of murder. Mendenhall now appeals, arguing that (1) the evidence is

insufficient to establish that Indiana has territorial jurisdiction (i.e., that the

murder occurred in Indiana) and (2) the trial court erred in admitting evidence

stemming from the search of his semi-truck in Tennessee because he was in

custody but not advised of his right to consult with an attorney before

consenting to the search, which Pirtle v. State, 323 N.E.2d 634 (Ind. 1975),

requires.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 2 of 18
[3] We conclude that the evidence is sufficient to prove territorial jurisdiction

because a reasonable inference from the evidence is that Mendenhall killed

Purpura at the truck stop in Indianapolis and didn’t keep her captive and alive

as he drove south on I-65. In addition, we conclude that the trial court did not

err in admitting evidence stemming from the Tennessee search. Accordingly,

we affirm the trial court.

Facts and Procedural History
[4] In July 2007, Detective Sergeant Pat Postiglione, a homicide detective with the

Metropolitan Nashville Police Department in Nashville, Tennessee, was

investigating a matter involving Truck Stops of America on North 1st Street in

Nashville. As part of his investigation, he had been reviewing security-camera

footage of semi-trucks coming and going from that location. A semi-truck with

a yellow tractor caught his attention as “a suspect or a witness.” Tr. Vol. 3 p.

137.

[5] Around 10:00 a.m. on July 12, Sergeant Postiglione went to Truck Stops of

America “to get on the street and see what [he was] seeing” on the video. Id.

While there, he saw a semi-truck with a yellow tractor that “looked similar to

the tractor that [he] had observed on the video” pull in. Id. Sergeant Postiglione

watched as the semi-truck parked “nose first,” even though semi-trucks

normally back in. Id. at 138. Sergeant Postiglione “pulled up behind” the semi-

truck, exited his car, and walked up to the truck. Id. at 173. As he did, the

person inside, later identified as Mendenhall, “pulled the curtain [to the sleeper

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 3 of 18
compartment] shut.” Id. at 138. Sergeant Postiglione “banged” on the door,

identified himself, and asked Mendenhall to step outside to speak to him. Id.

Ten seconds later, the curtain opened, and Mendenhall exited his semi-truck.

Id. Mendenhall’s shirt was open, he wasn’t wearing any shoes, and he was

stretching as if he had just been woken up. At that point, Sergeant Postiglione

observed “several drops that appeared . . . to be blood” on the inside of the

open driver’s door. Id. at 139. Sergeant Postiglione asked Mendenhall if he

could “look in his truck.” Id. at 140. Mendenhall agreed and signed a consent-

to-search form.

[6] Sergeant Postiglione started the search in the sleeper compartment of

Mendenhall’s semi-truck and “immediately noticed a large bag.” Id. at 141. He

opened it and saw women’s clothes, women’s shoes, and rags, “all blood

soaked” with “fresh” blood. Id. at 141-42. Sergeant Postiglione picked up the

bag, which was “fairly heavy” from the blood. Id. at 142. He asked Mendenhall

about the blood, and Mendenhall said it was from cutting his leg getting in and

out of his truck. Sergeant Postiglione asked Mendenhall to show him his leg,

and when he did, there was “nothing there.” Id. at 143. Sergeant Postiglione

then asked him about the clothes, and he said they belonged to his wife or

daughter. Sergeant Postiglione transported Mendenhall to the homicide office

for an interview.

[7] Mendenhall signed a waiver of Miranda rights and spoke to Sergeant

Postiglione. He said a woman had entered his semi-truck the night before, July

11, at the Flying J truck stop in Indianapolis sometime between 8:00 and 9:30

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 4 of 18
p.m. The Flying J is near Harding Street and I-465 on the south side of

Indianapolis in Marion County. Although the record doesn’t say that

Mendenhall expressly admitted shooting the woman, he did admit that she

“was shot” in the head and that “there was a plastic bag over her head” and

“[b]lack tape around [her] neck.” Id. at 144. Sergeant Postiglione asked

Mendenhall what the woman was shot with, and he said “his rifle,” which was

a .22 caliber rifle that was later recovered from his semi-truck. Id. Sergeant

Postiglione then asked if there would be blood on the rifle, and Mendenhall said

there “should be” and that it “would be from the girl from Indianapolis.” Id. at

1. Sergeant Postiglione also asked Mendenhall if his fingerprints would be on

the rifle, and he said “they should be” and that nobody else’s fingerprints would

be on it. Id.

[8] During the interview, Sergeant Postiglione noticed blood under Mendenhall’s

fingernails, which Mendenhall said was “from cleaning up from the girl from

Indianapolis.” Id. at 153. Contrary to his earlier statements, Mendenhall

admitted that the bloody clothes did not belong to his wife or daughter but “the

victim from Indianapolis.” Id. at 153-54. Mendenhall said he used the rags to

“wipe down the mattress and the floor” and then put them in the bag with the

bloody clothes. Id. at 153. He also admitted that he had driven south on I-65

from Indianapolis to Nashville.

[9] The Tennessee police obtained a search warrant for Mendenhall’s semi-truck.

Inside the truck they recovered a spent shell casing from a .22 caliber rifle, the

.22 caliber rifle Mendenhall told police was used in the shooting, an ATM card

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 5 of 18
belonging to Carma Purpura, who lived in Indianapolis, and ATM receipts

from a gas station on North Capitol Avenue in Indianapolis showing that

Purpura had tried to withdraw money at 6:19 p.m., 6:20 p.m., and 6:28 p.m. on

July 11 but had “insufficient funds.” Id. at 170; Ex. p. 55. The police also

recovered Purpura’s cell phone and a used condom and observed blood on the

floor and the mattress. DNA testing later showed that the blood on the clothes

was Purpura’s and that both Mendenhall’s and Purpura’s DNA was on the

condom.

[10] The Tennessee police called the Indianapolis Metropolitan Police Department

to alert them about a possible shooting at the Flying J. The Indianapolis police

searched the area around the Flying J for three days but didn’t find a body.

They recovered security-camera footage from the gas station on North Capitol

Avenue in Indianapolis showing Purpura, wearing the same clothes found in

Mendenhall’s semi-truck, at 7:36 p.m. on July 11.

[11] In April 2008, Purpura’s body still had not been found, but the State charged

Mendenhall with her murder in Marion County. By then, Mendenhall was

facing murder charges in two separate cases in Tennessee, and those cases were

tried first. Mendenhall was eventually convicted of murder in the Tennessee

cases and received two life sentences. 1

1
Mendenhall appealed his Tennessee murder convictions and sentences, and the Tennessee Court of
Criminal Appeals affirmed. See State v. Mendenhall, No. M2018-02089-CCA-R3-CD, 2020 WL 2494479
(Tenn. Crim. App. May 14, 2020) (victim Symantha Winters); State v. Mendenhall, No. M2010-02080-CCA-
R3-CD, 2013 WL 430329 (Tenn. Crim. App. Feb. 4, 2013) (victim Sara Hulbert). The Tennessee Supreme

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 6 of 18
[12] In August 2011, a Mammoth Cave employee was working near mile marker 8

on the Louie B. Nunn Parkway in southern Kentucky, which is close to I-65

and in between Indianapolis and Nashville, when he discovered a human skull.

The skull was approximately 75 feet below the road in a steep, brushy, wooded

area. The Kentucky State Police searched the area and located additional

human skeletal remains.

[13] The bones were examined by a forensic anthropologist with the Kentucky

Medical Examiner’s Office. The forensic anthropologist determined that the

person sustained a single gunshot wound to the head. The teeth from the skull

were compared to dental records of local missing people, but there was no

match. As a result, the forensic anthropologist sent two of the bones to the

Center for Human Identification at the University of North Texas. There, the

DNA was analyzed and entered into CODIS. 2 In October 2016, the DNA

sample was matched to Purpura.

[14] The State resumed its prosecution of Mendenhall in 2021, and jury trial was set

for January 2025. Before trial, Mendenhall moved to suppress the fruits of

Sergeant Postiglione’s July 12, 2007 search of his semi-truck in Tennessee, and

Court denied review in both cases. Mendenhall later sought post-conviction relief, which was also denied. No
evidence of these murders was presented to the jury in this case.
2
CODIS, which stands for the Combined DNA Index System, is a national database that stores DNA
profiles.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 7 of 18
a hearing was held.3 Mendenhall argued that his consent to search in Tennessee

was invalid under the Indiana Constitution because he was in custody but not

advised of his right to consult with an attorney before consenting, which Pirtle v.

State, 323 N.E.2d 634 (Ind. 1975), requires. In that case, the Indiana Supreme

Court held “that a person who is asked to give consent to search while in police

custody is entitled to the presence and advice of counsel prior to making the

decision whether to give such consent.” Id. at 640. Absent such a warning, any

evidence recovered during the search is inadmissible. Id. The State responded

that because the search was conducted in Tennessee, Pirtle did not apply. The

trial court agreed and denied the motion to suppress. See Tr. Vol. 3 p. 29. 4

[15] The case proceeded to jury trial, and Mendenhall objected to the admission of

the evidence stemming from Sergeant Postiglione’s search on the same grounds

that were argued at the suppression hearing. After the State rested, Mendenhall

moved for judgment on the evidence, arguing that the State failed to prove

venue in Marion County by a preponderance of evidence. See Appellant’s App.

Vol. 2 pp. 163-66; Cutter v. State, 725 N.E.2d 401, 408 (Ind. 2000) (“The right to

be tried in the county in which the offense was committed is a constitutional

3
Mendenhall moved to suppress all the evidence recovered from his semi-truck, his buccal swab, and his
statements to police. See Appellant’s App. Vol. 2 pp. 123-24.
4
The State also argued, and the trial court also found, that Mendenhall wasn’t in custody when he consented
to the search and therefore a Pirtle warning wasn’t required. On appeal, Mendenhall argues that he was in
custody. See Appellant’s Br. p. 22. The State didn’t respond to this argument in its brief. Because we reject
Mendenhall’s Pirtle claim for a different reason below, we do not address whether Mendenhall was in
custody.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 8 of 18
and a statutory right.”), reh’g denied. The trial court denied the motion but said

Mendenhall could argue venue during closing argument. See Tr. Vol. 4 pp. 56-

57.

[16] During closing argument, defense counsel argued that the State bore the burden

of proving venue by a preponderance of the evidence but that it didn’t present

any evidence that Purpura was killed in Marion County. See id. at 65-66.

Mendenhall didn’t separately argue that the State failed to prove territorial

jurisdiction (i.e., that the murder occurred in Indiana), and a jury instruction on

territorial jurisdiction was neither requested nor given. The jury found

Mendenhall guilty of murder, and the trial court sentenced him to 65 years, to

be served consecutive to his two life sentences in Tennessee.

[17] Mendenhall now appeals. 5

Discussion and Decision
I. The evidence is sufficient to prove territorial jurisdiction
[18] Mendenhall contends that the evidence is insufficient to establish that Indiana

has territorial jurisdiction. Territorial jurisdiction, which is governed by Indiana

Code section 35-41-1-1, is the authority of Indiana to prosecute a person for an

act committed within its territorial boundaries. Ortiz v. State, 766 N.E.2d 370,

374 (Ind. 2002); Riggle v. State, 151 N.E.3d 766, 769 (Ind. Ct. App. 2020).

5
We held oral argument on February 13, 2026, in the Indiana Supreme Court courtroom and hosted the
interns for the Indiana General Assembly. We thank counsel for their helpful presentations.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 9 of 18
“Although territorial jurisdiction is not necessarily thought of as an element of

the offense, the State is required to prove it beyond a reasonable doubt.” Riggle,

151 N.E.3d at 769.

[19] As an initial matter, we note that while the jury was told by defense counsel

that the State had to prove venue in Marion County by a preponderance of the

evidence, it was never instructed that the State had to prove territorial

jurisdiction in Indiana beyond a reasonable doubt. But Mendenhall doesn’t

claim any error in this regard, e.g., he doesn’t argue that the trial court

committed fundamental error by not giving an instruction even without a

request by the parties. In Ortiz, the Indiana Supreme Court addressed whether

the trial court erred in not instructing the jury on territorial jurisdiction. The

Court analyzed the issue under fundamental error because the defendant “failed

to tender his own instruction.” Ortiz, 766 N.E.2d at 375. The Court held that “if

there is no serious evidentiary dispute that the trial court has territorial

jurisdiction, then a special instruction on territorial jurisdiction need not be

given to the jury.” Id. at 376. The Court concluded that there was no

fundamental error because “[n]ot only was there sufficient evidence to prove

the [offenses] occurred in Indiana, but also [the defendant] never contested

jurisdiction at trial.” Id. The Court distinguished the case from McKinney v.

State, 553 N.E.2d 860 (Ind. Ct. App. 1990), trans. denied. In that case, this Court

reversed the defendant’s murder conviction and remanded for a new trial

because he disputed territorial jurisdiction at trial, and there was a dispute

concerning whether the crime occurred in Ohio or Indiana, but the trial court

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 10 of 18
rejected his jury instruction on territorial jurisdiction. Because Mendenhall

doesn’t argue that the trial court committed fundamental error by not

instructing the jury on territorial jurisdiction, we only address territorial

jurisdiction in the context of sufficiency of the evidence.

[20] We review a claim that Indiana lacked territorial jurisdiction as we would any

other sufficiency challenge. Ortiz, 766 N.E.2d at 374. Without reweighing the

evidence or judging witness credibility, we consider only the probative evidence

supporting the verdict and any reasonable inferences that may be drawn

therefrom. Id. We will affirm if the evidence and inferences could have allowed

a reasonable trier of fact to find that territorial jurisdiction existed. Id.

[21] “A person may be convicted under Indiana law of an offense if . . . either the

conduct that is an element of the offense, the result that is an element, or both,

occur in Indiana[.]” Ind. Code § 35-41-1-1 (b)(1) (emphases added). When, as

here, the offense is “homicide,” “either the death of the victim or bodily impact

causing death constitutes a result under subsection (b)(1). If the body of a

homicide victim is found in Indiana, it is presumed that the result occurred in

Indiana.” Id. at (c). 6

6
Kentucky law is similar. See Ky. Rev. St. Ann. § 500.060(3) (“When the offense is homicide, either the
death of the victim or the bodily impact causing death constitutes a ‘result’ within the meaning of subsection
(1)(a). If the body of a homicide victim is found within this state, it shall be prima facie evidence that the
result occurred within the state.”).

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 11 of 18
[22] Mendenhall admits that the evidence shows that Purpura entered his semi-truck

in Indianapolis and that she was killed in his truck. See Appellant’s Reply Br. p.

5 (admitting that the evidence shows that “Mendenhall met Purpura in

Indianapolis” and that “she was killed in Mendenhall’s truck”). But he asserts

that “nothing establishes where [his] truck was when Purpura was killed.” Id.

Mendenhall acknowledges that Indiana and Kentucky were “possible sites of

Purpura’s murder”; however, he says that “none of the State’s evidence tips the

scales toward Indiana,” much less establishes it beyond a reasonable doubt. Id.

at 6. If anything, he says, the fact that Purpura’s remains were found in

Kentucky suggests that she was killed there.

[23] The State responds that a reasonable inference from the evidence is that

Purpura was killed in Indiana, not Kentucky. We agree. The evidence shows

that Purpura lived in Indianapolis, and there was no indication that she

intended to leave Indianapolis the night she was killed. Purpura’s sister testified

that she had spoken to Purpura on July 10, and “everything [was] fine.” Tr.

Vol. 3 p. 134. In addition, shortly before entering Mendenhall’s semi-truck at

the Flying J in Indianapolis, Purpura learned that she had no money.

Mendenhall and Purpura then had sex as evidenced by the used condom with

their DNA found in the truck. A reasonable inference from the evidence is that

Purpura went to the truck stop to make some money, not to leave town,

meaning that she wouldn’t have willingly left the truck stop with Mendenhall,

and that he killed her there rather than keeping her alive and captive for the

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 12 of 18
long drive south on I-65 to the Louie B. Nunn Parkway in southern Kentucky.

The evidence is sufficient to prove that Indiana has territorial jurisdiction. 7, 8

II. The trial court did not err in admitting evidence stemming
from the search of Mendenhall’s semi-truck in Tennessee
[24] Mendenhall also contends that the trial court erred in admitting evidence

stemming from the July 12, 2007 search of his semi-truck in Tennessee because

he was in custody but not advised of his right to consult with an attorney before

consenting, in violation of Pirtle. 9 We generally review the admission of

evidence for an abuse of discretion. McCoy v. State, 193 N.E.3d 387, 391 (Ind.

2022). “However, when a constitutional violation is alleged, the proper

7
Mendenhall cites Sundling v. State, 679 N.E.2d 988 (Ind. Ct. App. 1997), reh’g denied, but we find that case
distinguishable. There, the defendant was charged with molesting two children from Michigan (A.W. and
B.W.) at an Indiana motel. We reversed the defendant’s conviction for one of the children (A.W.):
An examination of the record reveals that there is no evidence that A.W. was molested by
Sundling in Indiana. The State contends that the trial court relied upon B.W.’s testimony
regarding the location of Sundling’s alleged molestation of A.W. However, B.W.’s testimony
merely established that A.W. and two other children were present at the [Super] Motel 8 in
LaGrange, Indiana at the time B.W. was molested. Thus, although the prosecuting attorney
may have established that A.W. was present in the motel rooms during the molestation of B.W.,
the record is devoid of any evidence that Sundling also molested A.W. at the Super 8 Motel in
Indiana. Specifically, neither B.W. nor A.W. testified that Sundling molested A.W. while at the
motel in Indiana. To the contrary, A.W. testified that Sundling did not touch him at the Super 8
Motel in Indiana, but at a house in Sturgis, Michigan. Therefore, we must reverse and dismiss
Sundling’s conviction for molestation of A.W. for lack of territorial jurisdiction.
Id. at 991-92. As just discussed, this is not a case where “no evidence” supports territorial jurisdiction.
8
Mendenhall also argues that the evidence is insufficient to prove venue in Marion County. But because we
concluded above that the evidence is sufficient to prove beyond a reasonable doubt that Purpura was killed at
the Flying J in Indianapolis, which is in Marion County, we find that the evidence is sufficient to prove
venue in Marion County by a preponderance of the evidence. See I.C. § 35-32-2-1(c).
9
Mendenhall doesn’t make any Fourth Amendment arguments concerning the search of his semi-truck, as
the Tennessee courts have already addressed those arguments.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 13 of 18
standard of appellate review is de novo.” Ackerman v. State, 51 N.E.3d 171, 177

(Ind. 2016) (quotation omitted).

[25] Under the Fourth Amendment, a person’s valid consent to a search generally

eliminates the need for a search warrant. M.D. v. State, 108 N.E.3d 301, 304

(Ind. 2018). However, the Indiana Supreme Court has held that the Indiana

Constitution offers “broader protections” for individuals consenting to a search.

Id. Under Pirtle, before obtaining consent to search a home or vehicle, “police

must explicitly advise a person in custody of [their] right to consult with

counsel.” Id.; see also McCoy, 193 N.E.3d at 391 (“Pirtle applies when a person

(1) is in custody and (2) is asked by police to consent to a home or vehicle

search.”). Absent a Pirtle warning, “any evidence recovered during that search

must be suppressed at trial.” McCoy, 193 N.E.3d at 390. Pirtle is “unique” and

has “no federal counterpart.” M.D., 108 N.E.3d at 304. The principle behind

Pirtle is to “protect people from the most serious intrusions into privacy.”

Garcia-Torres v. State, 949 N.E.2d 1229, 1238 (Ind. 2011); see also M.D., 108

N.E.3d at 306 (“[O]ur concern in Pirtle, and in the ensuing cases, was that

consent to certain weighty intrusions carries a great risk of involuntariness.”). 10

[26] Mendenhall argues that “Pirtle applies even when the evidence was collected

outside” of Indiana. Appellant’s Br. p. 21. He claims that “[p]olice in Tennessee

may not be bound by Indiana law, but Indiana courts are.” Id. In support, he

10
For example, Pirtle doesn’t apply to pat-downs for weapons, buccal swabs, breath tests, blood draws, field-
sobriety tests, or drug-recognition exams. See Owens v. State, 246 N.E.3d 1256, 1262 (Ind. Ct. App. 2024).

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 14 of 18
cites Stidham v. State, 608 N.E.2d 699 (Ind. 1993). In 1991, 17-year-old Stidham

and his friends committed murder (and other crimes) in Indiana, visited friends

“whom they told of the killing,” and then drove to Illinois, where they were

arrested. Id. at 700. “After contacting police officers in Indiana, the Illinois

officers proceeded to Mirandize and question” Stidham without a parent or

other representative present, and he confessed. Id. Contrary to Illinois law,

Indiana law provided that a juvenile’s constitutional rights could only be

waived by the juvenile’s custodial parent, guardian, custodian, or guardian ad

litem if certain requirements were met. I.C. § 31-6-7-3(a) (1992) (now codified

at I.C. § 31-32-5-1(2)). 11 Indiana law also provided that if those requirements

were not met, the juvenile’s statement was not admissible as substantive

evidence at trial. I.C. § 31-6-7-3(c) (1992) (now codified at I.C. § 31-32-5-3).

[27] On appeal, Stidham argued that the trial court erred in admitting his confession

into evidence. Our Supreme Court agreed:

Under Illinois law, the police were not required to have a parent
or guardian present when they obtained [Stidham’s] statement.
However, the introduction in evidence of a statement made by a
person under eighteen years of age is forbidden by statute, Ind.
Code § 31-6-7-3, unless counsel representing the child, or the
child’s custodial parent, guardian, or guardian ad litem is present
and the child’s representative and the child waive his right to
remain silent. . . .

11
Section 31-6-7-3(a) also provided that a juvenile’s constitutional rights could be waived by the juvenile’s
attorney if the juvenile joined, but that provision was not at issue in Stidham.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 15 of 18
The State argues that since the statement of [Stidham] was
lawfully obtained in Illinois it could be introduced in evidence in
Indiana. The issue here is not the issue of the lawfulness of the
Illinois confession. There is no question that it in fact was taken
lawfully. The question is the admissibility of that statement
obtained in Illinois in a prosecution taking place in Indiana.

We are fully aware of the cases cited by the State wherein other
jurisdictions have held that in situations such as this, the
statement would be admissible in the prosecuting state. See State
v. Toone (1992), Tex. App., 823 S.W.2d 744; Tarawneh v. State
(1990), Fla. App., 562 So. 2d 770; People v. Accardo (1990) 195 Ill.
App. 3d 180, 141 Ill. Dec. 821, 551 N.E.2d 1349; State v. Mollica
(1989), 114 N.J. 329, 554 A.2d 1315; Pooley v. State (1985),
Alaska App., 705 P.2d 1293; People v. Blair (1979), 25 Cal. 3d
640, 159 Cal. Rptr. 818, 602 P.2d 738. However, to the extent
that those cases would permit introduction of a statement under
circumstances similar to those in this case, we reject their
authority.

Id. at 700-01. Accordingly, the Court reversed Stidham’s convictions and

remanded the case for a new trial.

[28] The State argues that Stidham doesn’t control here. It highlights that, “[u]nlike

Stidham, . . . there is no evidence that officers from Indiana and Tennessee were

in contact prior to obtaining Mendenhall’s consent to search his semi-truck.

There is no evidence that Indiana officers participated in any way in obtaining

Mendenhall’s consent to search.” Appellee’s Br. p. 31. That is, when Sergeant

Postiglione asked Mendenhall for consent to search his semi-truck in

Tennessee, he was investigating a Tennessee case and had no idea that a

potential crime in Indiana was involved. The Indianapolis police were only

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 16 of 18
contacted after Mendenhall consented to the search and evidence that Purpura

may have been killed was discovered.

[29] We agree with the State that this difference matters. We acknowledge, as

Mendenhall points out, that our Supreme Court’s analysis in Stidham did not

explicitly rely on the fact that the Illinois police contacted the Indiana police

before questioning Stidham without a parent or other representative present. See

Appellant’s Reply Br. pp. 10-11. But that is how the case unfolded. The Court

recognized that the majority approach is that the law of the state where the

search is conducted governs admissibility of the evidence. See, e.g., State v. Boyd,

992 A.2d 1071, 1084-85 (Conn. 2010). But it did not apply that approach given

the “circumstances” of the case. And those circumstances are that the Illinois

police interviewed a juvenile from Indiana in connection with an Indiana

murder—without a parent or other representative present in violation of

Indiana law—only after contacting the Indiana police. Those circumstances are

not present here. When Sergeant Postiglione asked Mendenhall for consent to

search his semi-truck in Tennessee, he had no idea that an Indiana crime was

implicated, and the Indianapolis police were only contacted after the fact.

Stidham therefore doesn’t control. The trial court did not err in admitting

evidence stemming from the July 12, 2007 search of Mendenhall’s semi-truck in

Tennessee.

[30] Affirmed.

Bradford, J., and Altice, J., concur.

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 17 of 18
ATTORNEY FOR APPELLANT
Casey Farrington
Marion County Public Defender Agency
Indianapolis, Indiana

ATTORNEYS FOR APPELLEE
Theodore E. Rokita
Attorney General
Michelle Hawk Kazmierczak
Deputy Attorney General
Indianapolis, Indiana

Court of Appeals of Indiana | Opinion 25A-CR-775 | March 12, 2026 Page 18 of 18