Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with four misdemeanors after a law enforcement officer stopped her vehicle for “unsafe lane movement,” conducted field sobriety tests on Defendant, which she failed, and discovered marijuana concealed in Defendant’s clothing. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to justify the stop. The trial court denied Defendant’s motion, concluding that, while a video from the officer’s vehicle did not show Defendant’s vehicle leaving the roadway, it did show Defendant’s vehicle veering onto the white fog line, and to the extent the officer’s testimony conflicted with the video, the testimony was more reliable than the video. The Supreme Court affirmed, holding that, under the totality of the circumstances, the officer’s conduct was reasonable, and the stop was constitutional. View "Robinson v. State" on Justia Law

Defendant pleaded guilty to driving while suspended as a habitual traffic violator (HTV). Defendant later filed a petition for post-conviction relief challenging an underlying offense for operating a vehicle while intoxicated (OWI) on grounds of the trial judge's alleged impropriety and the alleged violation of his right to counsel. The post-conviction court vacated the OWI conviction based on impropriety on the part of the trial judge. Defendant subsequently filed a motion to set aside his guilty plea because the OWI underlying offense had been set aside. The trial court granted the motion, set aside the guilty plea, and ordered Defendant's conviction expunged from his record. The Supreme Court affirmed, holding (1) although a defendant who pleads guilty to driving while suspended as a HTV may not later challenge the plea contending that an underlying offense has been set aside on grounds of procedural error, the defendant may be entitled to relief where an underlying offense has been set aside on grounds of material error; and (2) the State failed to meet its burden of demonstrating the trial court clearly erred in granting Defendant's motion to withdraw his guilty plea.View "State v. Oney" on Justia Law

Petitioner was charged with felony rape and related charges. Petitioner's case was first tried to a jury in 2008. The jury deadlocked on Petitioner's charges for felony rape and felony confinement, and a retrial was scheduled. After a second bench trial, the trial court found Defendant guilty of felony rape and not guilty of criminal confinement. The court of appeals affirmed. Petitioner's convictions were affirmed on appeal. Petitioner subsequently filed a petition for post-conviction relief, alleging, inter alia, that his trial counsel was ineffective for failing to object and/or move for a dismissal of the rape charge on state double jeopardy grounds. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) the "actual evidence" test announced in Richardson v. State is applicable to cases in which there has been an acquittal on one charge and retrial on another charge after a hung jury; and (2) the post-conviction court properly denied Petitioner's petition.View "Garrett v. State" on Justia Law

Defendant was convicted of felony criminal deviate conduct in 1998, was released from prison in 2000, and began registering annually as a sex offender. Indiana later expanded its registration requirements. Defendant petitioned for relief from the additional SVP obligations, arguing that they were an unconstitutional ex post facto law as applied to him. The trial court concluded in 2008 that retroactively classifying Defendant as an SVP under the expanded statutes would be unconstitutional. The State did not appeal the 2008 order, nor did the Department of Corrections (DOC) intervene to challenge it. In 2011, the State found Defendant had satisfied his registration obligations under the ten-year statute that existed at the time of his conviction. The DOC later filed a motion to correct error, arguing that Defendant's registration obligation from ten years to life was not an ex post facto violation. The trial court granted the motion and vacated the 2008 order. Defendant appealed, arguing that the 2008 order was res judicata against the DOC. The Supreme Court reversed, holding that even if the 2008 order was erroneous, it nevertheless became res judicata against the "State" - both the prosecutor and the DOC - when the State failed to appeal it.View "Becker v. State" on Justia Law

A driver hit Britney Meux, who later died from her injuries, and fled the scene. The State charged the alleged driver, Jason Cozmanoff, with thirteen crimes, including one count of reckless homicide. A few weeks later, Meux’s Estate sued Cozmanoff for wrongful death. The Estate then served Cozmanoff with discovery requests. If Cozmanoff were to invoke the Fifth Amendment and refuse to comply with the Estate’s requests, the civil jury could infer he was liable for causing Meux’s death. But if he were to provide discovery responses, the State could use his testimony and responses against him in his criminal trial. Cozmanoff moved to stay the civil case pending the resolution of his criminal prosecution, citing his Fifth Amendment privilege. The trial court granted a limited stay of discovery but ordered him to respond to the plaintiff’s complaint. The Supreme Court affirmed, holding that, under the circumstances, the trial court did not abuse its discretion in ordering a stay. View "Hardiman v. Cozmanoff" on Justia Law

I.T., who admitted to conduct that would be a Class B felony child molesting if committed by an adult, was ordered by the trial court to undergo therapeutic polygraph examinations. During one of those exams, I.T. admitted to molesting two other children. Based on those statements, the State filed a new delinquency petition. I.T. moved to dismiss the petition, arguing that the Juvenile Mental Health Statute, which bars a child’s statement to a mental health evaluator from being admitted into evidence to prove delinquency, barred the State’s evidence. The trial court granted the motion. The State appealed. The Supreme Court affirmed, holding (1) the State may appeal a juvenile court order that suppresses evidence if doing so terminates the proceeding; and (2) the Statute’s limited immunity prohibits both use and derivative use of a juvenile’s statements to prove delinquency. View "State v. I.T." on Justia Law

In 2012, the Common Council of the City of Evansville enacted an ordinance (“the Amending Ordinance”) that amended an existing smoking ban (“the Smoking Ban”). The Amending Ordinance extended the Smoking Ban to bars, taverns, and eating establishments but exempted riverboat casinos from the Smoking Ban. Various bars and private clubs brought actions against the City and its Council, claiming that the Amending Ordinance was unconstitutional. The trial court upheld the constitutionality of the Amending Ordinance, and the court of appeals affirmed. The Supreme Court reversed, holding (1) on its face, the Amending Ordinance violates the Equal Privileges and Immunities Clause of the Indiana Constitution because the disparate treatment is not reasonably related to the inherent differences between divergently-related classes; and (2) the Amending Ordinance must be stricken in its entirety. View "Paul Stieler Enters., Inc. v. City of Evansville" on Justia Law

After a jury trial, Defendant was convicted of murder, felony murder, robbery, and unlawful possession of a firearm by a serious violent felon. Defendant was sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) Ind. Code 35-50-2-9(1) is constitutional and its constitutionality does not require that the weighing of aggravators and mitigators be done beyond a reasonable doubt; (2) the trial court did not commit prejudicial error in its rulings regarding admission of evidence, use of an exhibit, instruction on felony murder, provision of a definition of asportation, and denial of surrebuttal; and (3) Defendant’s life sentence without the possibility of parole was appropriate. View "Inman v. State" on Justia Law

A fire destroyed a restaurant insured by Insurers. The Insurers brought suit against the City of Indianapolis and Veolia Water Indianapolis, LLC - a private, for-profit company responsible for operating the City’s water utility pursuant to a contract with the City - claiming that the water supply in the hydrants near the restaurant was inadequate to fight the fire. The City claimed sovereign immunity under both the common law and the Indiana Tort Claims Act (ITCA). Veolia also claimed common law sovereign immunity from liability. The trial court concluded that the City and Veolia were not entitled to sovereign immunity regarding the adequacy of the water supply. The Supreme Court (1) affirmed the trial court’s rulings that Veolia was not entitled to common law sovereign immunity and that the City was not entitled to statutory sovereign immunity from liability for damages resulting from an inadequate water supply; and (2) reversed the trial court’s ruling that the City was not entitled to common law sovereign immunity, as a governmental unit’s failure to provide adequate fire protection is an exception to governmental tort liability under Campbell v. State. View "Veolia Water Indianapolis, LLC v. Nat’l Trust Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of burglary as a class C felony and theft as a class D felony. The court of appeals affirmed. The Supreme Court granted transfer to address Defendant's argument that the trial court erred by admitting DNA evidence in violation of his Sixth Amendment right to confrontation. The Supreme Court affirmed the judgment of the trial court, holding that the trial court did not err in admitting certain DNA evidence, as the Constitution does not require a laboratory technician involved in the chain of custody of DNA evidence to testify at trial in order to satisfy the demands of a defendant's Sixth Amendment right of confrontation. View "Speers v. State" on Justia Law