Justia Indiana Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Barnes v. Indiana
A jury convicted Appellant Richard Barnes of misdemeanor charges involving battery, disorderly conduct, and resisting arrest. Appellant contested his conviction by raising technical errors at trial, specifically that the trial court did not advise the jury of his right to reasonably resist what he considered the officersâ unlawful entry to his apartment on the day he was arrested. The Supreme Court reviewed the trial record, and found that there is no right to âreasonably resistâ an entry by police officers. Furthermore, the Court held that the evidence was sufficient to support Defendantâs conviction, and affirmed the lower courtâs decision.
Wilkins v. Indiana
Facing felony drugs and firearms charges, Appellant Damion Wilkins sought to suppress evidence obtained when police executed a search warrant of a home. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
Lacey v. Indiana
Facing felony drugs and firearms charges, Appellant Cornelius Lacey, Sr. sought to suppress evidence obtained when police executed a search warrant of a home he was in. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
Konopasek v. Indiana
In June, 2008, Appellant Joshua Konopasek attended a house party in Rochester. At some point, he got into an altercation with another party-goer. The evening ended with Appellant shoving the other party-goer to the ground and stomping on his head. Appellant would later be charged with battery causing serious injury. Appellant claimed self-defense. On direct examination, Appellantâs attorney elicited testimony from him regarding his probationary status. On cross-examination, the State inquired further about appellantâs probation. Defense counsel objected that the stateâs inquiry was irrelevant. The trial court overruled the objection. Petitioner was found guilty as charged, and sentenced to eight yearsâ imprisonment, with six suspended and credit for time served. On appeal, Petitioner argued that there was insufficient evidence to convict him of battery, and that the trial court abused its discretion by admitting the evidence elicited by the State on his probation. The appellate court affirmed the trial court. The Supreme Court agreed too, holding that the Stateâs elicited testimony on the length of Petitionerâs suspended sentence was relevant and admissible. Furthermore, the Court found the evidence sufficient to support his conviction. The Court affirmed the lower courtsâ decisions.
Love v. Rehfus
Appellant-Plaintiff Bradley Love was a volunteer and part-time firefighter for the Sugar Creek Township Fire Department (Department) during the spring of 2006. During the Republican primary election that spring, Bob Boyer, a retired volunteer firefighter, challenged the incumbent, C.O. Montgomery, for the office of Sugar Creek Township Trustee. One of the Trusteeâs principal duties is to appoint a fire chief to oversee the Department. On April 24, 2006, a few weeks before the May 2nd primary, an email concerning Boyerâs political intentions was forwarded to Appellant by an acquaintance. Eventually a copy of Appellantâs email made its way to Appellee-Defendant Fire Chief Robert Rehfus. After consulting with Township counsel, Appellee sought to verify whether some of the facts in the email were true. Appellee was particularly offended by parts of the email. Concluding that Appellant made some false statements in the email, Appellee terminated Appellantâs employment for conduct unbecoming a firefighter and failing to be truthful in accordance with the Departmentâs General Orders. Appellant filed suit under 42 U.S.C. § 1983 in Hancock Circuit Court against both the Chief and the Township for violation of his constitutional rights under the First and Fourteenth Amendments. Appellees filed a motion for summary judgment arguing both that Appellantâs constitutional rights were not violated because false statements are not protected, and that the Township could not be held liable under § 1983 on a theory of respondeat superior. The trial court entered summary judgment on behalf of Appellees on both grounds. The appellate court reversed, finding that Appellantâs speech was protected under the First Amendment and that the Township was subject to liability under § 1983 because the Chief established final government policy respecting employment decisions within the fire department. The Supreme Court on review affirmed the appellate court decision, finding that the email was constitutionally protected speech, and that there were genuine issues of material fact that needed to be resolved in order to determine whether, as a matter of state law, the township is liable under 42 U.S.C. § 1983 for the Chiefâs actions.
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Constitutional Law, Indiana Supreme Court