Justia Indiana Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Hollowell v. State
Appellant was convicted of conspiracy to deal in cocaine as a class B felony and sentenced to an executed term of sixteen years. After an unsuccessful appeal, Appellant filed a pro se petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court denied relief. Still acting pro se, Appellant attempted to appeal the denial of his petition, but despite his “best efforts,” the appeal went awry. The court of appeals dismissed the appeal. The Supreme Court granted transfer, thereby vacating the court of appeals’ order. After full briefing on the merits, the Supreme Court affirmed the judgment of the post-conviction court, holding that the post-conviction court did not err in denying Appellant’s claim that counsel rendered ineffective assistance. View "Hollowell v. State" on Justia Law
Campbell v. State
After a jury trial, Defendant was found guilty of two counts of attempted murder, burglary resulting in serious bodily injury, aggravated battery, and battery. Defendant later filed a petition for post-conviction relief, alleging ineffective assistance of trial counsel, in part, for counsel’s failure to object to a supplemental jury instruction on the definition of “intentionally” that was given after deliberations had begun. The post-conviction court denied relief. The Supreme Court affirmed, holding that the instruction represented a correct statement of the law, and therefore, trial counsel in this case did not render ineffective assistance in failing to object to the instruction. View "Campbell v. State" on Justia Law
Carpenter v. State
While responding to a report of dogs fighting in Defendant’s backyard, law enforcement officers entered Defendant’s house to retrieve one bloody and aggressive dog and to ensure no one was injured. Once inside the home, the officers found marijuana plants. Based on the evidence found in Defendant’s home, Defendant was charged with five Class D felonies. Defendant moved to suppress the evidence, arguing that the search violated his rights under the federal and state Constitutions. The trial court denied Defendant’s motion and found him guilty of all charges. The court of appeals affirmed, concluding that exigent circumstances justified the officers’ warrantless entry into Defendant’s home. The Supreme Court granted transfer and reversed the trial court, holding that the officers’ entry into Defendant’s home was unreasonable and therefore impermissible under the Indiana Constitution, and therefore, the trial court erred by admitting the evidence recovered from Defendant’s home. View "Carpenter v. State" on Justia Law
Logan v. State
The State filed a class C felony child molestation charge against Appellant, and 1,291 days elapsed before the beginning of Appellant’s trial. Appellant was found guilty as charged and sentenced to six years executed. Appellant appealed, arguing that he was entitled discharge under Ind. R. Crim. P. 4(C) and that the unduly long delay violated his right to a speedy trial under the United States and Indiana Constitutions. The Supreme Court vacated Appellant’s conviction and ordered him released from incarceration, holding that despite the trial court’s technical compliance with Rule 4(c), the delay between the filing of the charge against Appellant and the beginning of Appellant’s trial violated his right to a speedy trial under the United States and Indiana Constitutions. Remanded. View "Logan v. State" on Justia Law
State v. Greene
After a bench trial, Petitioner was convicted of class B felony criminal confinement. Petitioner’s conviction was affirmed on appeal. Petitioner subsequently filed a petition for post-conviction relief, alleging that his trial and appellate counsel provided ineffective assistance. Specifically, Petitioner contended that had counsel presented Long v. State, he would not have been convicted of class B felony confinement or his conviction would have been set aside for insufficient evidence. The post-conviction court agreed with Petitioner and ordered his conviction reduced to a class D felony. The court of appeals affirmed. The Supreme Court reversed, holding that Petitioner mischaracterized Long, and accordingly, Petitioner’s counsels did not render ineffective assistance by failing to present an incorrect interpretation of case law. View "State v. Greene" on Justia Law
Old Nat’l Bancorp v. Hanover College
Hanover College, the beneficiary of two trusts, filed petitions requesting that the trusts be terminated. Old National Bancorp, d/b/a Old National Trust Company, as trustee for both trusts, filed responses to Hanover’s petitions. The trial court granted the petitions and ordered the two trusts dissolved and the trust assets distributed to Hanover. Rather than seek a stay of the trial court’s dissolution orders, Old National appealed. The court of appeals dismissed Old National’s appeal, concluding (1) Old National lacked standing in its representative capacity because it failed to obtain a stay of the trial court’s termination orders and was therefore no longer the trustee of the trusts; and (2) because Old National did not intervene in its individual capacity at trial it could not be an aggrieved party on appeal. The Supreme Court likewise dismissed Old National’s appeal, holding that the trustee lacked standing to pursue the appeal in its representative capacity and did not appeal in its individual capacity. View "Old Nat’l Bancorp v. Hanover College" on Justia Law
Posted in:
Constitutional Law, Trusts & Estates
Ind. Dep’t of State Revenue v. Caterpillar, Inc.
At issue in this case was whether Indiana’s tax statutes allow Caterpillar, Inc. to increase its Indiana net operating losses (NOLs) by deducting foreign source dividend income. Caterpillar commenced an original tax appeal in the Indiana Tax Court challenging the Indiana Department of State Revenue’s longstanding application of the Indiana tax statutes. The Tax Court entered summary judgment for Caterpillar, concluding that the Indiana NOL statute does not reference or incorporate the foreign source dividend deduction. The Supreme Court reversed, holding that Caterpillar may not deduct foreign source dividends when calculating Indiana NOLs, and Caterpillar did not meet its burden to show that disallowing the deduction discriminates against foreign commerce under the Foreign Commerce Clause. View "Ind. Dep’t of State Revenue v. Caterpillar, Inc." on Justia Law
Posted in:
Constitutional Law, Tax Law
Guilmette v. State
Law enforcement officers arrested Defendant on two counts of theft and seized his clothing, including his shoes, in accordance with their standard booking protocols. After police found what appeared to be blood under the laces of Defendant’s left shoe they subjected the shoe to laboratory testing. The testing revealed the presence of a murder victim’s DNA in that blood. Defendant was charged with murder and theft. Defendant moved to suppress the DNA evidence found on his shoe, arguing that the police should have obtained a separate warrant before subjecting the shoe to testing. The trial court denied the motion, and Defendant was subsequently convicted on all charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that police need not obtain a warrant before subjecting lawfully seized evidence to laboratory testing even if that evidence is unrelated to the crime for which the defendant is in custody. View "Guilmette v. State" on Justia Law
Halliburton v. State
After a jury trial, Defendant was convicted of murder and of being a habitual offender. The trial court sentenced Defendant to life in prison. Defendant appealed, arguing that the trial court erred in admitting certain evidence and in giving the jury an erroneous limiting instruction. The Supreme Court affirmed, holding (1) the trial court did not err by admitting certain photographs into evidence; (2) the trial court did not err in allowing the introduction of testimony from a state witness; (3) the trial court did not err in admitting evidence of other crimes; and (4) although the trial court erred in giving a limiting instruction directed to the testimony of a witness, the error was not fundamental.View "Halliburton v. State" on Justia Law
McIlquham v. State
Upon responding to a call about an unsupervised toddler wandering near an apartment-complex retention pond, Defendant informed the police that he was the child’s father. Defendant consented to police entry into his apartment, and the child’s mother, the leaseholder, consented to a full search. The police officers subsequently discovered contraband in the apartment and charged Defendant with unlawful possession of a firearm by a serious violent felon, neglect of a dependent, dealing marijuana, possessing marijuana, and possession of paraphernalia. Defendant pleaded guilty to the neglect and marijuana-possession counts, and the case proceeded to a trial on the remaining counts. During trial, Defendant filed a motion to suppress evidence found during law enforcement’s pat-down search and subsequent search. The trial court denied the motion. Defendant was acquitted of dealing marijuana but found guilty on the remaining charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, as Defendant consented to police entering the apartment, Defendant’s movements justified a pat-down, and the mother gave her consent to search the rest of the apartment. View "McIlquham v. State" on Justia Law