Justia Indiana Supreme Court Opinion Summaries

Articles Posted in May, 2011
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In September 1997, the State charged Defendant Charles Boyle with felony and misdemeanor motor vehicle violations. Defendant pled guilty to the felony "operation of a motor vehicle while a habitual traffic offender" charge against him. The trial court accepted the plea, and entered its judgment of conviction. Several years after the case had concluded, Defendant petitioned for post-conviction relief, and the trial court modified his conviction. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that the trial court lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

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In August 2000, Defendant Jeffrey Brunner entered a guilty plea to "operating while intoxicated" (OWI). At the time of his plea, Defendant had an OWI within the previous five years that made the August, 2000 offense a felony. When going over Defendant's constitutional rights at trial, the court said "it [was] theoretically possible that a person found guilty of a . . . felony can have judgment of conviction entered and be sentenced as if it were a. . . misdemeanor." Defendant moved the court to modify its order of conviction to reduce the felony to a misdemeanor. The court granted the motion to modify, and the State appealed. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that trial court indeed lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

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Defendant Tyrus Coleman shot Anthony Dye and Jermaine Jackson during a confrontation on Defendantâs property. The State charged Defendant with murder and attempted murder. At trial, Defendant testified and admitted to the shootings, but maintained that he shot in self-defense. Defendant was acquitted on the murder charge, but a mistrial was entered on the attempted murder charge. Before he could be retried, Defendant filed a motion to dismiss the attempted murder charge arguing that the State was âcollaterally estoppedâ from bringing the same case against him, and that if allowed to proceed, the second trial would constitute double jeopardy. The trial court denied that motion, and a retrial was held. The second jury found Defendant guilty as charged. The trial court sentenced Defendant to forty-five yearsâ imprisonment. A divided appellate court reversed Defendantâs conviction on collateral estoppel grounds. The Supreme Court held that collateral estoppel and double jeopardy did not preclude the State from retrying Defendant after a mistrial had been declared. The Court reversed the appellate courtâs decision, and affirmed the trial courtâs judgment.

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A jury convicted Appellant Richard Barnes of misdemeanor charges involving battery, disorderly conduct, and resisting arrest. Appellant contested his conviction by raising technical errors at trial, specifically that the trial court did not advise the jury of his right to reasonably resist what he considered the officersâ unlawful entry to his apartment on the day he was arrested. The Supreme Court reviewed the trial record, and found that there is no right to âreasonably resistâ an entry by police officers. Furthermore, the Court held that the evidence was sufficient to support Defendantâs conviction, and affirmed the lower courtâs decision.

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The Indiana Attorney General (AG) sought to recover a tax refund issued to Aisin USA Manufacturing, Inc. (Aisin) at the Superior Court. The AG appealed the courtâs decision in favor of Aisin, arguing that because it was a tax matter, the Superior Court did not have jurisdiction to hear matters that âarose underâ the state tax laws. Upon review, the Supreme Court held that the case could proceed in the Superior Court. The Court found that despite the AGâs characterization of the case, the refund was a result of accounting and clerical errors within the Department of Revenue that were wholly unrelated to any interpretation or application of tax law. The Court remanded the case for further proceedings in Superior Court.

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Facing felony drugs and firearms charges, Appellant Damion Wilkins sought to suppress evidence obtained when police executed a search warrant of a home. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.

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Facing felony drugs and firearms charges, Appellant Cornelius Lacey, Sr. sought to suppress evidence obtained when police executed a search warrant of a home he was in. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.

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The City of Indianapolis abandoned the âBarrett Lawâ method of financing sewer improvements in favor of a new system that imposes less of a financial burden on property owners. To ease the transition, the City discharged all outstanding Barnett Law assessments owing as of November 1, 2005, but did not give refunds to those property owners who had previously paid their Barrett Law assessments in full or in part. Plaintiffs Christine Armour and other property owners who had paid their Barrett Law assessments in full petitioned the City for refunds in the amount equal to the assessments discharged in 2005. In their claim, Plaintiffs alleged that the City had violated their federal constitutional rights to due process and equal protection under the Fourteenth Amendment. At trial, the court granted Plaintiffsâ motion for summary judgment, and the City appealed. On appeal, Plaintiffs abandoned their due process claim and sought to have the equal protection claim sustained. The appellate court affirmed the trial courtâs judgment. The City appealed again. Upon review, the Supreme Court held that the City did not violate the Equal Protection Clause of the Fourteenth Amendment because forgiving the outstanding assessment balances was rationally related to a legitimate governmental interest. The Court reversed the decision of the trial court and remanded the case for further proceedings.

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In June, 2008, Appellant Joshua Konopasek attended a house party in Rochester. At some point, he got into an altercation with another party-goer. The evening ended with Appellant shoving the other party-goer to the ground and stomping on his head. Appellant would later be charged with battery causing serious injury. Appellant claimed self-defense. On direct examination, Appellantâs attorney elicited testimony from him regarding his probationary status. On cross-examination, the State inquired further about appellantâs probation. Defense counsel objected that the stateâs inquiry was irrelevant. The trial court overruled the objection. Petitioner was found guilty as charged, and sentenced to eight yearsâ imprisonment, with six suspended and credit for time served. On appeal, Petitioner argued that there was insufficient evidence to convict him of battery, and that the trial court abused its discretion by admitting the evidence elicited by the State on his probation. The appellate court affirmed the trial court. The Supreme Court agreed too, holding that the Stateâs elicited testimony on the length of Petitionerâs suspended sentence was relevant and admissible. Furthermore, the Court found the evidence sufficient to support his conviction. The Court affirmed the lower courtsâ decisions.

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Appellant Martin Serrano lost his truck in a forfeiture action based on the presence of cocaine residue found in the carpet of the vehicle, and on a box of quarters. Appellant challenged the sufficiency of the evidence, contending that the State failed to prove that the presence of cocaine in his truck was anything more than "incidental or fortuitous." The Court of Appeals agreed with Appellantâs argument. The Supreme Court found that though Appellant admitted he was a cocaine user, âthere are numerous ways that cocaine residue may have made its way into the truck that [did] not involve the use of the vehicle in furthering the possession of cocaine.â The Supreme Court affirmed the appellate courtâs decision.