Convicted Muncie child molester loses appeal over decades-old cases

MUNCIE, Ind. – A man convicted of crimes he committed nearly three decades ago will continue to serve the prison sentence he was sentenced to in 2021. It comes as the Indiana Court of Appeals rejects his appeal to overturn the convictions.

James E. Samuels attempted to overturn a July 2021 Delaware County conviction for child molestation and sexual gratification by proxy. He was convicted after an investigation into allegations that he sexually abused two children and ordered two children to perform sexual acts with each other in the late 1990s.

Police arrested Samuels in May 2018 after an investigator interviewed two people who said they were sexually abused by him as children. While Samuels was on trial, both children testified to a 2000 investigation into the assaults. However, the appeal document says the detective in the case testified that he tried to locate tapes from the investigation, but other than the initial DCS report, he found no tapes.

In his appeal, Samuels alleged that his due process rights were violated because the state failed to keep any records that might have been created in this investigation. He cited Brady v. Maryland for his justification.

In that case, the U.S. Supreme Court ruled that “the prosecution’s suppression of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or sentencing, regardless of the good or bad faith of the prosecution.

The Indiana Court of Appeals said U.S. Supreme Court case law clarified Brady’s scope. The Indiana Supreme Court explained:

[The defendant] . . . to complain[s] that the state failed to keep and provide him with the interview notes of an FBI agent.

Adopting the United States Supreme Court’s decision in California v. Trombetta, 467 US 479, 104 S. Ct. 2528, 81 L. Ed. 2d 413 (1984), this Court stated that the scope of the state’s obligation to preserve exculpatory evidence is:

limited to evidence likely to play a significant role in the defense of the suspect. To meet this standard of constitutional significance, the evidence must both possess exculpatory value that was apparent before the evidence was destroyed and be of such a nature that the defendant would not be able to obtain evidence. comparable by other reasonably available means.

In the Court of Appeals opinion, the court ruled that Samuels failed to show that the handwritten interview notes played a significant role in his defense. He also said Samuels provided them with no basis to conclude that the FBI agent’s notes would have shown whether a witness made the statements or whether the agent’s recollections were incorrect.

At most, the opinion said that the notes could have been potentially useful as additional evidence. If the failure to preserve useful evidence was in bad faith on the part of the state, it would have violated the 14th Amendment. However, the pre-trial destruction of the notes, which were transferred to other documents made available to the defence, was done in good faith as part of normal practice.

After the notice was issued, the Delaware County District Attorney released a statement saying:

“I am satisfied with the outcome of the appeal. This is another child predator that has been taken off the streets. He can no longer prey on innocent children. I am proud of my Steve Sneed and Bryce Winslow for their hard work and dedication in this matter.

Eric Hoffman, Delaware County District Attorney

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