INDIANAPOLIS – The Indiana Supreme Court upheld the murder conviction for a Gas City woman who killed her stepdaughter in 2019.
Amanda Carmack was sentenced to life without parole in the death of 10-year-old Skylea Carmack. A jury convicted her of murder.
Carmack and her attorney contended that she acted in “sudden heat” when she killed her stepdaughter and should be charged with voluntary manslaughter. The Indiana Supreme Court heard arguments in the case in September.
Carmack’s attorney argued Skylea’s behavior pushed her stepmother to the “breaking point.” Carmack was caring for and homeschooling six other children: three of her own and three of her brother’s children.
The final straw for Carmack was when her stepdaughter stole a bracelet and the girl’s father (Carmack’s husband) failed to immediately address it.
Carmack reported her stepdaughter missing in August 2019, leading to a statewide Silver Alert and a large search. Days later, police found Skylea’s body inside a trash bag in a shed on the family’s property. Carmack admitted she killed her daughter.
An autopsy found Skylea died from asphyxia due to ligature strangulation; she was found with a double-knot ligature made of clothing around her neck. There were also signs of manual strangulation, the medical examiner determined, but the ligature strangulation had been responsible for killing the 10-year-old.
In its decision, the Indiana Supreme Court ruled that the killing didn’t meet the standard for “sudden heat.” The court acknowledged that Carmack had been angry at her stepdaughter but said the behavior “was inadequate to elicit sudden heat.”
“At most, Carmack’s subjective parenting issues with [her stepdaughter] could have been addressed through rote disciplinary measures—not strangulation. Nothing about these facts suggests she was adequately provoked,” the court wrote.
The court also believed Carmack had an adequate “cooling off” period, noting that she’d called her husband about her daughter’s behavior around 3:30 p.m. and didn’t take immediate action. She texted her husband between 8 p.m. and 9 p.m. to say, “I think we have a problem” and then reported her stepdaughter missing.
Because of the lack of “sudden heat” and the existence of a “cooling off” period, the court decided Carmack’s actions didn’t fit the standard for manslaughter and affirmed her murder conviction and sentence.
“Because we find the State sufficiently carried its evidentiary burden in negating the mitigating factor and voluntary manslaughter requirement of ‘sudden heat,’ we affirm Carmack’s murder conviction and LWOP [life without parole] sentence,” the court wrote in its conclusion.