Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, murder in the perpetration of criminal deviate conduct, and related crimes. The State sought a sentence of life without parole, but in the penalty phase, the jury was unable to reach a unanimous verdict as to whether the State had proven its charged aggravating circumstance. Nonetheless, the trial court sentenced Defendant to life imprisonment without the possibility of parole on the murder count. The Supreme Court remanded for a revised sentencing order as to the judge’s conclusion that life imprisonment was the appropriate sentence. On remand, the trial court affirmed the sentence. Defendant appealed, arguing, on grounds not previously raised, that the trial court’s imposition of a life sentence violated the Sixth Amendment because the aggravating factor supporting the sentence was not determined by the trier of fact during the penalty phase. The Supreme Court agreed, holding that the trial court committed reversible error by imposing a sentence of life without parole under the circumstances. In the interests of judicial economy, the Court further exercised its appellate prerogative to sentence Defendant to a term of years. View "Lewis v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, robbery, and conspiracy to commit robbery. Defendant was sentenced to life imprisonment without possibility of parole. Defendant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) Defendant was not denied due process in discovery; (2) Defendant was not denied his right to a speedy trial; (3) the trial court did not abuse its discretion in denying Defendant’s requests to hire DNA and blood spatter experts at public expense; (4) the trial court did not commit fundamental error by allowing unknown witnesses to remain in the courtroom during opening statements despite a separation order; (5) the trial court did not abuse its discretion by allowing the State’s entomologist to testify; (6) the trial court properly admitted evidence found in Defendant’s van; and (7) sufficient evidence supported Defendant’s convictions. View "Griffith v. State" on Justia Law

Defendant was arrested and charged with several drug-related offenses. Defendant filed a motion to suppress all evidence seized as a result of a search of his home conducted without a warrant. The trial court largely denied the motion. After a jury trial, Defendant was found guilty of four drug-related counts. On appeal, Defendant argued that the police made a warrantless entry into his home without valid consent and that the police conducted an illegal protective sweep once inside. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress all evidence seized in the search of his home, holding (1) under the circumstances of this case, Defendant’s house guest, who answered the door to Defendant’s home, did not have the apparent authority to consent to police entry; and (2) because the police did not have a warrant or warrant exception to justify entry into Defendant’s home, the subsequent searches, including the protective sweep, were unlawful, and the fruits of those searches must be suppressed. View "Bradley v. State" on Justia Law

Defendant was charged with operating a vehicle with an alcohol concentration equivalent (ACE) of 0.08 or more. At trial, the judge instructed the jury to presume Defendant’s ACE at the time of the offense based on a chemical test that was performed within three hours of his being stopped by law enforcement. The instruction told the jury it “shall presume,” yet also stated that “the presumption is rebuttable.” Defendant appealed, arguing that the instruction amounted to fundamental error because it improperly relieved the State of its burden to prove each element beyond a reasonable doubt. The Court of Appeals agreed and reversed Defendant’s conviction, concluding that the instruction did not make clear that the presumption was merely permissible. The Supreme Court granted transfer, thus vacating the opinion below, and affirmed, holding that the instruction did not unconstitutionally shift the State’s burden of proof in violation of Defendant’s due process rights. View "Pattison v. State" on Justia Law

Thomas Hale appealed his conviction for dealing in methamphetamine, on the sole grounds that the trial court abused its discretion in failing to grant him, at public expense, depositions of two State’s witnesses. After review, the Indiana Supreme Court found that prior precedent compelled the Court to agree with Hale and reverse his conviction. The Court took the opportunity of this case to provide guidance as to how trial courts should address such motions in the future. View "Hale v. Indiana" on Justia Law

Defendant was charged with two D-felony counts of strangulation and two counts of domestic battery, one of which was elevated to a D-felony based on a prior domestic battery conviction. Defendant moved to bifurcate the D-felony domestic battery charge. The jury found Defendant guilty of the misdemeanor domestic battery and not guilty of the strangulation charges. The judge then asked Defendant’s counsel whether Defendant would like to waive his right to a jury trial on the D-felony domestic battery charge. Defendant remained silent while his attorney told the judge that Defendant intended to proceed as a bench trial on the second phase of the bifurcated trial. After a bench trial on the second phase Defendant was found guilty of the D-felony domestic battery. Defendant appealed, arguing that he did not validly waive his state and federal constitutional jury trial rights. The Supreme Court reversed Defendant’s conviction for D-felony domestic battery, holding that the trial court committed fundamental error by proceeding to trial absent personal waiver of his constitutional jury trial right by Defendant himself. Remanded for a new trial. View "Horton v. State" on Justia Law

After a jury trial, Defendant was found guilty of battery as a class A misdemeanor. Under the provisions of Ind. Code 35-38-1-7.7(a), the trial court also determined that Defendant committed a crime of “domestic violence,” which determination rendered Defendant ineligible to possess a firearm. Defendant appealed, arguing, in part, that the firearm restriction amounted to additional punishment above the statutory maximum for misdemeanor battery, and because the facts supporting the enhancement were not submitted to a jury, the determination violated Defendant’s Sixth Amendment right to trial by jury. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to trial by jury; and (2) the evidence was sufficient to sustain the determination that Defendant committed a crime of domestic violence. View "Hitch v. State" on Justia Law

In 2005, Indianapolis passed a non-smoking ordinance (“Ordinance”) banning smoking in public businesses but providing certain exemptions. A 2012 amendment removed the exemption for bars and taverns that had liquor licenses and neither served nor employed anyone under the age of eighteen. The amendment, however, exempted businesses licensed as satellite gambling facilities by April 1, 2012. Plaintiffs, certain bars and restaurants, claimed the Ordinance violated the Equal Privileges and Immunities Clause of the Indiana Constitution because it applied to them but exempted satellite gambling facilities. The trial court granted summary judgment for Defendants, concluding that the Ordinance’s exemptions were not unconstitutional. The Court of Appeals reversed and severed the satellite facility exemption, concluding that the Ordinance’s exemption for satellite facilities violated the Equal Privileges and Immunities Clause. The Supreme Court granted transfer and affirmed the trial court’s grant of summary judgment in favor of the City, holding that the Ordinance does not violate the Indiana Constitution’s Equal Privileges and Immunities Clause because the exemption for satellite gambling facilities is reasonably related to the inherent differences distinguishing satellite gambling facilities from bars and restaurants and because the Ordinance does not create a monopoly or treat similarly situated classes disparately. View "Whistle Stop Inn, Inc. v. City of Indianapolis" on Justia Law

In 2005, Indianapolis passed a non-smoking ordinance (“Ordinance”) banning smoking in public businesses but providing certain exemptions. A 2012 amendment removed the exemption for bars and taverns that had liquor licenses and neither served nor employed anyone under the age of eighteen. The amendment, however, exempted businesses licensed as satellite gambling facilities by April 1, 2012. Plaintiffs, certain bars and restaurants, claimed the Ordinance violated the Equal Privileges and Immunities Clause of the Indiana Constitution because it applied to them but exempted satellite gambling facilities. The trial court granted summary judgment for Defendants, concluding that the Ordinance’s exemptions were not unconstitutional. The Court of Appeals reversed and severed the satellite facility exemption, concluding that the Ordinance’s exemption for satellite facilities violated the Equal Privileges and Immunities Clause. The Supreme Court granted transfer and affirmed the trial court’s grant of summary judgment in favor of the City, holding that the Ordinance does not violate the Indiana Constitution’s Equal Privileges and Immunities Clause because the exemption for satellite gambling facilities is reasonably related to the inherent differences distinguishing satellite gambling facilities from bars and restaurants and because the Ordinance does not create a monopoly or treat similarly situated classes disparately. View "Whistle Stop Inn, Inc. v. City of Indianapolis" on Justia Law