Son’s convictions for murdering parents upheld

A Lake County man convicted of murdering his parents failed to convince the Indiana Court of Appeals that a search of his family’s home was unconstitutional, thus allowing his murder convictions to stand.

The case of Thomas Jeffrie Snow v. State of Indiana, 18A-CR-578, began on Sept. 30, 2013, when Clifford and Joyce Snow did not call their daughter, Julie Niemeyer, on her birthday like they usually did. When Niemeyer called the next day, her brother, Thomas Snow, said their parents were out walking the dogs. Niemeyer asked Snow to have her parents call her back, but they never did.

Meanwhile that same day, Snow visited his parents’ friends and told them his parents were in Germany for two weeks. Snow repeated the Germany story to additional neighbors but told others his father had died and his mother was visiting Niemeyer in Missouri.

Two days later, Snow was involved in a traffic stop that turned into a police chase. Snow got away, but his truck was found in Illinois with a garbage bag containing, among other items, a drill.

Later that month, after being told by a cousin that Clifford had died, Niemeyer requested that the Lake County Sheriff’s Department conduct a welfare check. Upon Niemeyer’s request, officers forced their way into the home, smelled the odor of decomposition and identified a female body in the bathroom. Law enforcement then obtained a warrant for the house and found Clifford’s body in the garage.

An ensuing search for Snow found him in Minnesota, where he led local law enforcement on a high-speed chase and identified himself as “Jack the Ripper.” Among other items, officers found Snow with carbon copies of checks and credit cards.

When Lake County officers picked him up in Minnesota, Snow was charged with multiple felonies, including two counts of murder and resisting law enforcement, as well as felony and misdemeanor traffic violations. Before his trial, Snow moved to suppress the evidence found in his residence, and his trial counsel continually objected to the evidence’s admission.

The evidence was admitted, and at trial an expert opined that Clifford and Joyce had died in mid-September 2013. The state presented evidence that Snow had used their credit cards and checks after their deaths, while Niemeyer noted her parents’ stash of money was missing. Further, another expert testified that holes found on the victims’ bodies likely came from an instrument used for drilling.

A jury found Snow guilty as charged, and the Indiana Court of Appeals upheld his convictions Thursday. Judge Elizabeth Tavitas, writing for a unanimous panel, upheld the admission of the evidence found in Snow’s home, rejecting his Fourth Amendment and Article 1, Section 11 arguments.

Specifically, Tavitas said there were exigent circumstances to support the initial warrantless search of the home, noting Niemeyer had not heard from her parents in weeks and had been told by relatives that her parents were either missing or dead. Further, though Snow waived his argument under the Indiana Constitution, Tavitas said waiver notwithstanding, the search did not violate Article 1, Section 11 because the Litchfield v. State, 824 N.E.2d 356, 359 (Ind. 2005), factors weighed in favor of the search.

“Although Snow did live at the residence, the victims, who were the individuals believed to be in need of aid, owned the residence,” the judge wrote. “The officers received no response when they knocked and were left with few options when they believed persons in need of aid to be inside the home.” 

The appellate court also rejected Snow’s sufficiency argument, pointing to evidence of Snow living in the residence with his parents, checks written to Snow from his parents after the presumed time of their deaths and efforts to clean and repaint the part of the home where Clifford and Joyce were killed.

“The fact that a murder weapon was not found is not determinative,” Tavitas concluded. “Clifford and Joyce were found approximately one month after the estimated times of their deaths, and the jury reasonably could have concluded Snow had time to discard the murder weapon. Snow’s argument is simply a request for us to reweigh the evidence, which we cannot do.”