Conviction upheld for man who killed wife over mental health issues

A man who shot and killed his wife during an argument about her mental health issues could not convince the Indiana Court of Appeals on Friday that his decades-long sentence for murder was inappropriate.

Patrick Elliott was convicted of felony murder and Class A misdemeanor false informing after fatally shooting his wife in the chest while the couple argued about her refusal to receive help for her mental health diagnoses.

Donita, who married Elliott in 1999, was subsequently diagnosed with bipolar disorder and generalized anxiety disorder. The couple over the course of the next several years struggled in their on-and-off again relationship, ending things for the final time when Elliott reached out to law enforcement about committing his wife to a psychiatric or mental hospital.

After calling for a wellness check to his home that prompted Donita to leave in anger, Elliott spoke with responding officers about how to defend himself if necessary. But the consensus of the deputies and Donita’s psychiatrist was that the requirements for an involuntary commitment of Donita had not been met.

After everyone left the home, Elliott hid a handgun in the home and later shot Donita with it when she returned that evening to retrieve her things. Elliott recorded the interaction leading up to the murder, which law enforcement used to confirm that he lied about the events of Donita’s killing. Specifically, that she did not approach him with a knife to attack him, but that he planted the knife after shooting her.

Elliott likewise admitted this to his longtime pastor, Keith Evans of the Reformed Presbyterian Church of Lafayette, who visited him several times while in jail. However, prior to the start of his trial, Elliott moved to suppress all statements made to Evans, arguing that they were inadmissible, privileged communications. The trial court denied that motion and the pastor testified about what Elliott had admitted to him over Elliott’s objection. A jury found Elliott guilty, and he then admitted to a firearm enhancement, receiving an aggregate 75-year sentence.

An appellate panel affirmed his sentence and conviction, first rejecting Elliott’s argument that Evans should not have been allowed to testify to the incriminating statement because the statement was an admission made to a clergyman “in the course of discipline enjoined by” his pastor’s church.

“Elliott attempts to distinguish his case from (Ball v. State, 275 Ind. 617, 419 N.E.2d 137 (1981)) and (Mullins v. State, 721 N.E.2d 335, 338 (Ind. Ct. App. 1999)). However, we find his attempts unavailing and conclude that Pastor Evans’ testimony was properly admitted,” Senior Judge John Sharpnack wrote for the appellate panel.

In light of Ball, Mullins and Bonham v. State, 644 N.E.2d 1223 (Ind. 1994), the appellate court concluded that Elliott’s statement to the pastor was not made “in the course of discipline enjoined by” the pastor’s church and therefore, the trial court did not err in admitting his testimony.

It further found nothing inappropriate about his aggregate sentence, noting that the sentence was not inappropriate in light of the nature of the offenses or his character.

The appellate court therefore affirmed in the case of Patrick M Elliott v. State of Indiana, 19A-CR-02498.