State of Indiana v. Bryan D Lyons

Summary

The Indiana Supreme Court held that a trial court may exclude evidence as a discovery sanction when exclusion is the only remedy that avoids substantial prejudice or when the discovery violation reflects egregious culpability. Although continuing the trial cured any actual prejudice caused by the late disclosure, the trial court reasonably found that the investigating officer had misled the parties and the court by concealing that he had converted the stipulated polygraph examination into an inadmissible investigatory examination. The court therefore affirmed the exclusion of the evidence.