Crossland v. Indiana: Refining Standards for Impartial Juries, Venue Transfers, Peremptory Challenges, and Defense Rights

Introduction

In Chelsea L. Crossland v. State of Indiana (Ind. 2025), the Indiana Supreme Court addressed two pivotal issues in criminal procedure: the contours of the right to an impartial jury in the face of prejudicial pretrial publicity and the right to present a complete defense when confronted with hearsay exclusions. Chelsea Crossland was convicted of murder and neglect of a dependent resulting in death after her five-year-old son, Christian, was found starved and battered to death. On appeal, she argued that (1) negative publicity and alleged juror bias required a venue change and additional peremptory challenges, and (2) the trial court’s exclusion of certain impeachment evidence violated her constitutional rights. The Court’s decision affirms the convictions and clarifies the standards for managing prejudicial publicity, peremptory challenge exhaustion, and the admissibility of defense evidence.

Summary of the Judgment

The Indiana Supreme Court unanimously affirmed Crossland’s convictions and life‐without‐parole sentence.

The Court held that exposure of some jurors to prejudicial news articles did not automatically require a venue change absent affirmative proof that those jurors could not set aside biases.
It clarified that peremptory challenges cannot be “refunded” simply because the trial court denies for‐cause strikes; a defendant must use peremptory strikes strategically once the court finds no cause for removal.
The Court rejected Crossland’s argument that the hearsay exclusion of impeachment evidence violated her right to present a defense, finding that the rules of evidence may limit evidence even in the face of constitutional claims, and that any error was harmless given the overwhelming proof of guilt.

Analysis

Precedents Cited

Ward v. State (810 N.E.2d 1042): Held that extensive prejudicial publicity plus jurors who could not set aside bias required change of venue.
Specht v. State (734 N.E.2d 239): Established two‐part test for venue change—prejudicial publicity and juror prejudice—and recognized trial court discretion.
Elsten v. State (698 N.E.2d 292): Confirmed that exposure alone does not disqualify jurors so long as they can set aside preconceived notions.
Oswalt v. State (19 N.E.3d 241) and Whiting v. State (969 N.E.2d 24): Defined “incompetent” juror for cause, contrasted with “objectionable” juror subject only to peremptory challenge.
Bixler v. State (471 N.E.2d 1093): Requires exhaustion of peremptory challenges to preserve venue-change issues on appeal.
Chambers v. Mississippi (410 U.S. 284) and Crane v. Kentucky (476 U.S. 683): Recognized constitutional right to present complete defense but allowed evidentiary rules to curb unreliable hearsay.
Van Arsdall (475 U.S. 673): Harmless-error standard for constitutional evidentiary exclusions.

Legal Reasoning

The Court’s reasoning can be divided into two major strands:

Impartial Jury and Venue
Under Indiana and federal constitutions, jurors must be able to set aside prior knowledge and decide based on evidence. The Court reaffirmed the two-part test from Specht and Ward requiring (1) prejudicial publicity and (2) a seated juror’s inability to be impartial. Although three jurors admitted exposure to news accounts, each affirmed during voir dire that they could follow instructions, presume innocence, and base verdict solely on trial evidence. No evidence showed community-wide bias or actual juror prejudice. Thus, denial of the venue-change motion was within the trial court’s broad discretion.
Peremptory vs. For-Cause Challenges
The Court clarified the distinction between “incompetent” jurors (biased and removable for cause) and “objectionable” jurors (removable only through peremptory strikes). Crossland argued that the trial court forced her to exhaust all peremptory strikes on seven jurors who should have been struck for cause, leaving none to remove a juror she found objectionable. The Court held that none of the seven displayed disqualifying bias. Each was rehabilitated, affirming the ability to judge impartially. Consequently, Crossland had no entitlement to an extra peremptory challenge.
Right to Present a Complete Defense and Hearsay
Crossland sought to impeach a key witness (Riddle) with out‐of‐court statements contradicting his trial testimony. The trial court excluded this evidence as hearsay. The Supreme Court held that the Constitution does not override established hearsay rules that serve interests of reliability and fairness. Even if exclusion were erroneous, it was “harmless beyond a reasonable doubt,” given the overwhelming evidence of abuse, starvation, and Christian’s traumatic death.

Impact

This decision will guide future Indiana courts and practitioners in several respects:

Pretrial Publicity: Merely showing that jurors read or saw news coverage—even if inflammatory—will not suffice. Defendants must show that specific jurors could not set aside biases.
Jury Selection: Defendants must distinguish between for-cause challenges (limited to biased jurors) and peremptory challenges. Exhaustion of peremptory strikes against objectionable but not biased jurors does not implicate due process.
Defense Evidence: Reaffirms that constitutional rights to present witnesses and impeach testimony remain subject to sound evidentiary rules, particularly hearsay prohibitions. Harmless-error analysis will often apply when the factual record is overwhelming.
Trial Strategy: Encourages more precise voir dire questioning and strategic peremptory use rather than reliance on potential refunds when for-cause motions are denied.

Complex Concepts Simplified

Impartial Jury: A juror who can lay aside prior knowledge and follow the judge’s instructions, deciding solely on evidence presented.
Change of Venue: Moving trial to a different county when pretrial publicity prevents seating an impartial jury.
For-Cause Challenge: Removal of a juror shown to be actually biased or legally disqualified (“incompetent”).
Peremptory Challenge: A limited strike allowing a party to exclude any juror for any reason except race, gender, or religion.
Hearsay: An out-of-court statement offered to prove the truth of its contents; generally inadmissible because the original speaker cannot be cross-examined.
Harmless Error: A legal mistake that did not influence the outcome of a trial and thus does not warrant reversal.

Conclusion

Crossland v. State reaffirms and refines critical aspects of Indiana criminal practice. It underscores that:

Defendants must demonstrate actual juror prejudice—not merely exposure to news—to secure a venue change.
The strategic use of peremptory challenges remains the responsibility of counsel; denied for-cause strikes do not entitle a defendant to additional peremptories.
The constitutional right to present a defense coexists with robust evidentiary rules; hearsay exclusions may stand so long as any error is harmless in light of the evidence.

These principles will shape how trial courts manage juror impartiality, counsel balance peremptory allocations, and judges apply hearsay rules in the pursuit of fair and reliable outcomes.