Justia Indiana Supreme Court Opinion Summaries

A trial court found Lisa Gray guilty of possessing marijuana as a class A misdemeanor. The court of appeals set aside the conviction on the grounds of insufficient evidence. At issue on appeal was whether the trial court properly found Gray had constructive possession of the marijuana when it was found on the floor of her apartment and Gray's son testified that the marijuana belonged to him. The Supreme Court granted transfer, vacated the court of appeals, and affirmed the trial court, holding that there was substantial evidence of probative value from which the court could have found beyond a reasonable doubt that Gray committed the crime. View "Gray v. State" on Justia Law

After a jury trial, Appellant Otha Hamilton was convicted of one count of molesting a child for an incident in which Appellant's nine-year-old step-granddaughter performed oral sex on him. Hamilton was sentenced to the maximum sentence of fifty years in prison. Hamilton appealed, arguing, inter alia, that the sentence was inappropriate given the nature of his offense and his character. The court of appeals affirmed the conviction and sentence. The Supreme Court affirmed Hamilton's conviction but revised his sentence, holding that, given the nature of Hamilton's sexual misconduct, the sentence imposed by the trial court was inappropriate. Remanded with instructions to enter an amended sentence of thirty-five years in prison. View "Hamilton v. State" on Justia Law

Jeffery Cain was convicted of murder and robbery and sentenced to life without the possibility of parole. Cain appealed his conviction and sentence, claiming that a co-defendant's testimony was improperly admitted at the guilt phase of his trial and that the prosecutor made inappropriate arguments during the sentencing phase. The Supreme Court affirmed, holding (1) under the circumstances, the trial court was well within its discretion to deny Cain's motion to exclude the co-defendant's testimony; and (2) although the prosecutor inaccurately portrayed education programs for offenders in her closing argument during the sentencing phase of Cain's trial, the prosecutor's statements did not qualify as fundamental error. View "Cain v. State" on Justia Law

Defendant Nathan Brock was charged with one count of violating Ind. Code 9-30-10-17, which makes it a felony for a habitual traffic violator to operate a motor vehicle after his or her driving privileges have been forfeited for life, and one count of felony resisting law enforcement. The trial court granted the State's motion for a mistrial due to improper prejudicial comments made by defense counsel during closing argument. Before the second trial was set to begin, Brock filed a motion to dismiss on double-jeopardy grounds. The trial court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, although Defendant did not consent to the mistrial, his second trial did not violate the Double Jeopardy Clause of the Fifth Amendment because the trial court did not abuse its discretion in concluding that a mistrial was justified by manifest necessity. View "Brock v. State" on Justia Law

Mother's parental rights to her Child were terminated by the juvenile court after Mother's incarceration. The court of appeals affirmed. Mother appealed, alleging several due process violations on the part of the Department of Child Services (DCS). The Supreme Court affirmed, holding (1) if any error existed in DCS's failure to locate Mother, which resulted in Mother's absence from the termination hearing, it did not substantially increase the risk of error in her termination proceeding; (2) a misrepresentation by DCS on an affidavit, in this limited instance, did not violate Mother's due process rights; (3) a delay from DCS in serving Mother with a Child in Need of Services petition upon locating Mother was inappropriate, but a reversal was not warranted in this case because the dilatory action did not result in fundamental error or deprive Mother of due process; (4) whether an incarcerated parent is permitted to attend a termination hearing is within the sound discretion of the trial court judge, and therefore, Mother's due process rights were not violated by her absence from the trial; and (5) the evidence in this case supported the trial court's findings that termination of the parent-child relationship was in Child's best interests. View "Z.G. v. Dep't of Child Servs." on Justia Law

While driving on a county road, Pamela Price encountered ice across the roadway and lost control of her vehicle, sustaining personal injury and property damage. Earlier that morning, after a different driver lost control of his vehicle at the same location, a deputy of the county sheriff department arrived at the scene and advised the county highway department of the icy condition. Price filed a complaint against, among others, the sheriff department and highway department, alleging negligence. The sheriff department and highway department filed a motion to dismiss for failure to state a claim upon which relief can be granted, which the trial court denied. The sheriff department sought interlocutory review. The court of appeals granted review and affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the trial court, holding that because the sheriff department neither owned, maintained, nor controlled the county road, it did not owe a common law duty to warn the public of known hazardous conditions upon the roadway. View "Putnam County Sheriff v. Price" on Justia Law

Desmond Turner was found guilty of murder, felony murder, criminal confinement, robbery, and burglary. Turner appealed, alleging that the trial court erred in admitting four types of evidence. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in permitting firearms tool mark identification testimony; (2) testimony related to the firearms identification did not deny Turner the right of confrontation and did not violate Indiana's rule against hearsay; (3) the trial court did not err in admitting evidence of Turner's alleged other crimes, wrongs or acts; (4) testimony of a witness was hearsay and the trial court erred in admitting it; but (5) the admission of the hearsay testimony did not require reversal because Turner's conviction was supported by substantial evidence of guilt apart from the challenged testimony. View "Turner v. State" on Justia Law

A jury found Richard Barnes guilty of battery on a police officer and resisting arrest. The Supreme Court affirmed Barnes's conviction. Subsequently, Barnes petitioned for rehearing, which the Supreme Court granted. At issue in the appeal was whether the trial court erred when it refused to instruct the jury that Barnes, a suspected spouse abuser, had the right to get physical with the police officers if he believed their attempt to enter his residence was legally unjustified. The Court continued to affirm Barnes's conviction, holding that the Castle Doctrine, which authorizes a person to use reasonable force against another person to prevent the unlawful entry of his dwelling, is not a defense to the crime of battery or other violent acts on a police officer. View "Barnes v. State" on Justia Law

Defendant Cedric Lewis was pulled over for speeding and arrested when the police officer discovered Lewis's driver's license had been suspended. After ordering Lewis out of the vehicle, the officer stuck his head inside the car to tell a passenger to get out and immediately saw a handgun near the driver's seat. Lewis moved to suppress the gun, arguing that the officer violated the Fourth Amendment by sticking his head into the car to search for weapons. The trial court overruled Lewis's objection and found him guilty of unlawful possession of a firearm by a serious violent felon. The court sentenced Lewis to twelve years in prison. The Supreme Court affirmed the judgment of the trial court, holding (1) the officer's discovery of the gun was not an impermissible search, and (2) the trial court' sentence, just two years above the advisory, was not inappropriate. View "Lewis v. State" on Justia Law

Defendant Arturo Garcia-Torres was convicted of rape, attempted rape, and two counts of burglary and was sentenced to thirty-six years in prison. Defendant challenged the use of DNA evidence gathered when police obtained a cheek swab while Defendant was in custody after the attempted rape, arguing it was an invalid search under the Fourth Amendment. The Supreme Court affirmed, concluding (1) the cheek swab was a search requiring its own separate probable cause proceedings; (2) the cheek swab was taken under a valid consent; and (3) a Pirtle warning requiring the presence and advice of counsel prior to consenting to a search was not required. View "Garcia-Torres v. State" on Justia Law