Justia Indiana Supreme Court Opinion Summaries

Alva Curtis, a fifty-nine year-old man with a developmental disability, was arrested and charged with residential entry, battery, and criminal mischief. The trial court denied Curtis's motion to dismiss. The court of appeals reversed, finding the pending criminal charges violated Curtis's right to due process. The Supreme Court reversed and remanded, holding Curtis was entitled to dismissal under Indiana Criminal Rule 4(C), which provides that a defendant may not be held to answer a criminal charge for greater than one year, because the days that count toward Rule 4(C) in this case exceeded 365. The Court also held (1) that Curtis waived his constitutional speedy-trial claims because he failed to raised the claims for the first time on appeal, and (2) Curtis did not have a valid due process claim on fundamental-fairness grounds where, under State v. Davis, the trial court had not involuntarily committed the defendant or made an appropriate finding that Curtis will never be restored to competency. View "Curtis v. State" on Justia Law

Johnson, the defendant in this criminal case, wrote the trial court judge a few months prior to trial complaining that his public defender, who had a history of neglecting clients, had been neglecting his case. The judge forwarded the complaint to the public defender's office and took no further action. Johnson appealed, arguing that the judge's failure to inquire further into his complaint violated his Sixth Amendment right to the effective assistance of counsel. The court of appeals found that the trial court handled Johnson's complaint reasonably. The Supreme Court affirmed the defendant's conviction, but held that the trial court had a duty to receive assurances from the public defender's office that Johnson's complaint had been addressed. The trial court judge's failure, however, (1) did not violate Johnson's right to the effective assistance of counsel, and (2) did not prejudice the defendant because Johnson failed to renew his objection at trial and because defense counsel appeared at trial and subjected the state's case to meaningful adversarial testing. View "Johnson v. State" on Justia Law

In district court, appellant was convicted of one count of Class A felony child molestation based on penetration and one count of Class C felony child molestation based on fondling. The Court of Appeals reversed appellantâs Class C felony conviction because the charge was filed well after the applicable five-year statute of limitations. At issue was whether, under Ind. Code 35-41-4-2, the statute of limitations was tolled when appellantâs coercive authority over the victim ceased in 1991 or when the victim disclosed the abuse to the authorities in 2008. The Supreme Court reversed, holding that once concealment of evidence by the defendant has been established, statutes of limitations for criminal offenses are tolled under the statute until a prosecuting authority becomes aware or should have become aware of sufficient evidence to charge a defendant. The Court also held that there was no double jeopardy violation because each challenged offense was established by separate and distinct facts.