Justia Indiana Supreme Court Opinion Summaries

Plaintiff brought several claims against multiple defendants arising out of his incarceration for a probation violation that occurred after his term of probation had expired. The trial court dismissed Plaintiff’s claims against all defendants. The court of appeals affirmed. Plaintiff sought transfer, contending that his claim against four individual probation officers under 42 U.S.C. 1983 was incorrectly dismissed for failure to state a claim. The Supreme Court granted transfer and reversed dismissal of Plaintiff’s section 1983 claim against the individually-named probation officers, holding that Plaintiff’s complaint stated a claim for relief under section 1983 against these defendants. View "Thornton v. State" on Justia Law

Plaintiffs, as a certified class, challenged the constitutionality of the program utilized by the Indiana Bureau of Motor Vehicles (BMV) in the processing of applications for personalized license plates (PLPs), arguing that the decision making process used in denying or revoking PLPs violates the First Amendment and the Due Process Clause. The trial court granted summary judgment in favor of the class, concluding that the statute that authorizes the BMV to refuse to issue PLPs and its related policies are vague, overbroad, and lacking in content-neutrality and that the Bureau violates due process safeguards by providing insufficient reasons for a denial or revocation of a PLP. The Supreme Court reversed, holding (1) PLPS are government speech; and (2) therefore, the statute and policies at issue in this case are constitutional. View "Comm’r of Ind. Bureau of Motor Vehicles v. Vawter" on Justia Law

After a jury trial, Defendant was convicted of class A felony child molesting. The court of appeals reversed Defendant’s conviction and remanded for a new trial, holding that the trial court abused its discretion in denying Defendant’s motion to compel the victim’s mother to answer a deposition question about an incident in the victim’s past and in excluding from evidence the substance of a phone conversation with the victim’s mother in which she and the victim discussed the incident. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding that the trial court’s alleged errors, even if considered violations of Defendant’s Sixth Amendment right to confrontation, were harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary, a class C felony. The Court of Appeals reversed the conviction, finding that the conviction was obtained through the State’s knowing use of perjured testimony. The Supreme Court granted transfer, thus vacating the opinion of the Court of Appeals, and affirmed the conviction, holding (1) Defendant’s due process rights were not implicated by the inconsistent testimony, as the State notified opposing counsel and the court of the conflicting testimony and proactively drew attention to the discrepancies in the testimony throughout the trial, thus permitting the jury to fully function as an informed fact finder; and (2) the incredible dubiosity rule was not applicable to this case. View "Smith v. State" on Justia Law

Defendant was living in the residence of an individual who was home home detention under Community Corrections supervision when community corrections officers went into the residence to conduct a warrantless search to ensure Sullivan’s compliance with the conditions of the program. The ensuing search uncovered illegal drugs in the common areas in the residence as well as drugs and drug paraphernalia in Defendant’s private bedroom. Defendant was charged with maintaining a common nuisance and other drug-related offenses. The trial court granted Defendant’s motion to suppress in part, concluding that the Community Corrections officers had consent to search the common areas of the residence but not Defendant’s private bedroom. The Supreme Court reversed, holding that all of the evidence seized from the compliance search was the result of an improper entry and search because the home detention participant had agreed to written conditions of his participation that consented only to searches upon probable cause, which was wholly lacking in this case. Remanded with instructions to grant the motion to suppress in its entirety. View "State v. Vanderkolk" on Justia Law

After a jury trial, Defendant was found guilty of three counts of murder. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s conviction and death sentence but remanded with instructions to issue a new sentencing order consistent with this opinion, holding (1) the trial court did not err by denying Defendant’s for-cause challenges to certain prospective jurors; (2) the trial court did not err in denying Defendant’s motions for mistrial; (3) the trial court did not abuse its discretion in instructing the jury; (4) the trial court did not err by refusing to allow a witness to answer a question posed by a juror; (5) the State did not commit prosecutorial misconduct during closing arguments in the penalty phase of trial, but the remarks were not so prejudicial to Defendant’s right of fundamental due process as to make a fair trial impossible; (6) Defendant’s death sentence was appropriate; and (7) the trial court exceeded its statutory authority by ordering Defendant’s death sentences to be served consecutively. View "Isom v. State" on Justia Law

After a jury trial, Defendant was convicted of criminal confinement and battery. Defendant appealed, arguing that his convictions violated the prohibition against double jeopardy under the Indiana Constitution and common law and seeking sentence review. The Supreme Court vacated Defendant’s conviction for battery and its concurrent three year sentence but affirmed Defendant’s conviction and eight year sentence for criminal confinement, holding (1) Defendant’s two convictions do not violate the common law but do violate the Double Jeopardy Clause of the Indiana Constitution under the actual evidence test; and (2) Defendant failed to demonstrate that his sentence is inappropriate for his character and the nature of the offense. View "Hines v. State" on Justia Law

In 2000, Appellant was diagnosed with paranoid schizophrenia. In 2004, while unprovoked, Appellant fired a shotgun several times at multiple vehicles, including a police cruiser. The jury returned verdicts of guilty but mentally ill on four counts of Class A felony attempted murder. Appellant was sentenced to an aggregate sentence of 120 years. The court of appeals reversed Appellant’s convictions, concluding that (1) jury clearly erred in rejecting Appellant’s insanity defense, and (2) the admission of evidence regarding Appellant’s post-arrest silence and request for counsel, and the prosecution’s closing arguments relying on those instances as evidence of sanity, violated Appellant’s constitutional due process rights. The Supreme Court granted the State’s petition to transfer, thereby vacating the Court of Appeals opinion, and affirmed the the jury's verdict finding Appellant guilty but mentally ill, holding (1) there was sufficient evidence for a jury to draw a reasonable inference that Defendant was able to appreciate the wrongfulness of his conduct at the time of the offense; (2) there was no due process violation; and (3) Appellant’s sentence was appropriate. View "Myers v. State" on Justia Law

Police officers asked Defendant to step out of his truck during a traffic stop and made their permission conditional on a pat-down. During the pat-down, the officers discovered marijuana on Defendant’s person. Defendant then admitted he had a pipe in his truck. Defendant was charged with possession of marijuana and possession of paraphernalia. The trial court granted Defendant’s motion to suppress the marijuana and the pipe. The Court of Appeals affirmed on different grounds, concluding that Defendant’s consent to the pat-down was invalid because the choice of being patted down as a condition of exiting the vehicle or else remaining in the vehicle unsearched was inherently coercive and rendered Defendant’s consent involuntary. The Supreme Court reversed, holding (1) it is not inherently coercive for police to give conditional permission to step out of the vehicle, subject to the motorist’s consent to a pat-down; and (2) any extension of the search from Defendant’s initial consent was the product of his subsequent consent and not of improper police conduct. View "State v. Cunningham" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and felony arson resulting in serious bodily injury. The jury recommended the death penalty, and the trial court sentenced Defendant accordingly. The Supreme Court affirmed the convictions and sentence, holding (1) the trial court did not err in excluding a prison administration expert from testifying that Defendant could safely be incarcerated for the remainder of his natural life; (2) there was sufficient evidence to support the convictions; (3) the trial court did not commit reversible error in refusing to excuse twelve jurors for cause; (4) Defendant was not entitled to a mistrial after a juror placed a note in the jury room thanking jurors for their service to the deceased; (5) the district court did not err in refusing to suppress statements Defendant made to police; (6) the trial court did not abuse its discretion in sentencing Defendant to death; and (7) the jury and the trial court properly considered and weighed Defendant’s offered mitigating circumstances. View "Weisheit v. State" on Justia Law