Justia Indiana Supreme Court Opinion Summaries

After being charged with two counts of child molesting, defendant Ronald Fromme asked the circuit court to require Crisis Connection, an organization that provides services to victims of sexual abuse and domestic violence, to provide him with all of its records relating to the alleged victims. Crisis Connection argued that the state victim advocate privilege gave it authority to refuse the request. The circuit court ordered Crisis Connection to deliver the records to the court for its in camera review before turning them over to Fromme. Upon review, the court of appeals concluded that he privacy interest asserted by Crisis Connection was not strong enough to bar the in camera review. On appeal, the Supreme Court vacated the decision of the appellate court and reversed the order of the trial court, holding the state's compelling interest in maintaining the confidentiality of information gathered in the course of serving the needs of victims of violence and abuse was not outweighed by Fromme's right to present a complete defense. Accordingly, Fromme did not have a constitutional right to an in camera review of the records. In the absence of a violation of Fromme's constitutional rights, the Court applied the victim advocate privilege. View "Crisis Connection, Inc. v. Fromme" on Justia Law

Elmer Baker was charged with three counts of child molesting. At a retrial in 2008, Baker was convicted as charged. Baker appealed, arguing partly that the convictions were not sustained by evidence of jury unanimity. The court of appeals affirmed. On transfer, the Supreme Court held that the state may in its discretion designate a specific act on which it relies to prove a particular charge, but if the state decides not to so designate, then the juror should be instructed that in order to convict the defendant the juror must either unanimously agree that the defendant committed the same act or acts or that the defendant committed all of the acts described by the victim. In this case the state did not designate which specific act it would rely upon to support the charging information and the jury instruction did not correctly advise the jury what it must agree upon to convict Baker. The Court concluded, however, that because Baker did not object to the instruction the issue was waived, and because Baker did not demonstrate that the instruction error so prejudiced him that he was denied a fair trial, the judgment of the trial court was affirmed. View "Baker v. State" on Justia Law

Thirteen-year old D.M. and his friend were arrested after breaking in to a residence and taking several items of personal property. According to his mother, while D.M. was being held in a police cruiser he was prevented from speaking to his mother by police officers. Later D.M. and his mother signed a juvenile waiver acknowledging they understood D.M.'s rights. D.M. then confessed to a detective. The juvenile court found D.M. to be a delinquent child for committing acts that would have been felonies if they had been committed by an adult and placed D.M. on probation. D.M. appealed, arguing that he had not been given an opportunity for meaningful consultation with his mother and that the waiver of his rights was not knowing and voluntary. The court of appeals affirmed, and the Supreme Court granted transfer. The Court held (1) the police provided D.M. an opportunity for meaningful consultation with his custodial parent before the waiver of his rights, and (2) there is substantial evidence of probative value that D.M.'s rights were waived voluntarily and therefore the court did not err in admitting D.M.'s confession. View "D.M. v. State" on Justia Law

In 2008, Douglas Denzell was charged with resisting law enforcement and public intoxication. The trial court found Denzell incompetent to stand trial and committed him to the Division of Mental Health and Addiction for treatment. In 2009, after psychiatric evaluation reports revealed Denzell could be restored to competency, the trial court entered a commitment order. Denzell filed a motion to dismiss the charges. The trial court denied the motion. The court of appeals affirmed, finding the pending charges did not violate Denzell's right to due process on fundamental-fairness grounds because, under State v. Davis, there was no determination that Denzell would never be restored to competency. The Supreme Court affirmed, holding the appellate court was correct in rejecting Denzell's due process argument. The Court noted, however, that the standard the lower court used in evaluating Denzell's claim was too stringent. Although relevant precedent is a necessary consideration when evaluating defendants' fundamental-fairness claims, there may be factual scenarios that differ from Davis and other relevant precedent that still fall within the parameters of a due process violation. View "Denzell v. State" on Justia Law

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.

In September 1997, the State charged Defendant Charles Boyle with felony and misdemeanor motor vehicle violations. Defendant pled guilty to the felony "operation of a motor vehicle while a habitual traffic offender" charge against him. The trial court accepted the plea, and entered its judgment of conviction. Several years after the case had concluded, Defendant petitioned for post-conviction relief, and the trial court modified his conviction. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that the trial court lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

In August 2000, Defendant Jeffrey Brunner entered a guilty plea to "operating while intoxicated" (OWI). At the time of his plea, Defendant had an OWI within the previous five years that made the August, 2000 offense a felony. When going over Defendant's constitutional rights at trial, the court said "it [was] theoretically possible that a person found guilty of a . . . felony can have judgment of conviction entered and be sentenced as if it were a. . . misdemeanor." Defendant moved the court to modify its order of conviction to reduce the felony to a misdemeanor. The court granted the motion to modify, and the State appealed. The Court of Appeals overturned the trial court on grounds that the lower court lacked statutory authority to modify the conviction. Upon review, the Supreme Court found that trial court indeed lacked statutory authority to modify Defendant's conviction. The Court remanded the case back to the trial court to reinstate Defendant's original conviction.

Defendant Tyrus Coleman shot Anthony Dye and Jermaine Jackson during a confrontation on Defendantâs property. The State charged Defendant with murder and attempted murder. At trial, Defendant testified and admitted to the shootings, but maintained that he shot in self-defense. Defendant was acquitted on the murder charge, but a mistrial was entered on the attempted murder charge. Before he could be retried, Defendant filed a motion to dismiss the attempted murder charge arguing that the State was âcollaterally estoppedâ from bringing the same case against him, and that if allowed to proceed, the second trial would constitute double jeopardy. The trial court denied that motion, and a retrial was held. The second jury found Defendant guilty as charged. The trial court sentenced Defendant to forty-five yearsâ imprisonment. A divided appellate court reversed Defendantâs conviction on collateral estoppel grounds. The Supreme Court held that collateral estoppel and double jeopardy did not preclude the State from retrying Defendant after a mistrial had been declared. The Court reversed the appellate courtâs decision, and affirmed the trial courtâs judgment.