Justia Indiana Supreme Court Opinion Summaries

Kimberly Anderson was charged with three felonies after stabbing her boyfriend with a boxcutter and threatening to kill him. Before trial, she entered a plea agreement with the State, pleading guilty to two charges—felony domestic battery and felony intimidation. In exchange, the State dropped one charge, refrained from adding another, and agreed to a maximum executed sentence of four years, with the specific sentence left to the trial court’s discretion. The agreement included a provision in which Anderson waived her right to appeal any sentence imposed within the terms of the agreement.At the sentencing hearing in the Marion County Superior Court, the judge reviewed the plea agreement with Anderson, confirmed her understanding, and heard arguments from both sides regarding aggravating and mitigating factors. The court ultimately sentenced Anderson to three years executed and three years suspended to probation. After sentencing, the court mistakenly told Anderson she could appeal her sentence, prompting her to do so. Anderson’s appeal to the Indiana Court of Appeals argued that the trial court abused its discretion by considering improper factors and failing to recognize significant mitigating evidence. The State moved to dismiss the appeal based on the waiver, and a divided motions panel of the Court of Appeals dismissed the appeal. Anderson then sought transfer to the Indiana Supreme Court.The Indiana Supreme Court held that a sentence is “illegal”—and thus not subject to an appeal waiver—only if it is outside the statutory range or unconstitutional. Anderson’s sentence was within the statutory range and not unconstitutional; her arguments concerned alleged abuse of discretion, not illegality. The Court found the appeal waiver valid and comprehensive, and dismissed Anderson’s appeal. View "Kimberly R. Anderson v. State of Indiana" on Justia Law

A juvenile, D.W., was charged with child molestation and dissemination of material harmful to minors. During the initial hearing, the juvenile court allowed D.W.'s counsel to waive a formal advisement of rights without personally confirming with D.W. if he agreed to the waiver. After a fact-finding hearing, D.W. was adjudicated delinquent. D.W. appealed, arguing that the juvenile court erred by not providing a formal advisement of rights and that his counsel's waiver was invalid because it was not confirmed that D.W. knowingly and voluntarily joined the waiver.The Marion Superior Court adjudicated D.W. delinquent, and the Indiana Court of Appeals affirmed the decision. The Court of Appeals found that the delinquency petition provided sufficient notice of the charges and that any errors in the advisement of rights did not rise to the level of fundamental error. The court also noted that D.W. exercised his constitutional rights during the proceedings.The Indiana Supreme Court reviewed the case and agreed that the juvenile court erred by not providing a formal advisement of rights and that the waiver by D.W.'s counsel was invalid because the court did not personally confirm the waiver with D.W. However, the Supreme Court found the error to be harmless because D.W.'s substantial rights were not affected. D.W. was represented by counsel, exercised his constitutional rights, and there was no indication that the lack of formal advisement impacted the outcome of the case. Therefore, the Indiana Supreme Court affirmed the juvenile court's delinquency adjudication. View "D.W. v. State" on Justia Law

Gage Peters was convicted of criminal sexual abuse in Illinois in 2013, which required him to register as a sex offender for ten years. He moved to Indiana in 2016 and registered as required. In 2021, Peters vacationed in Florida, where he signed a form agreeing to lifetime registration as a sex offender. After returning to Illinois and then moving back to Indiana in 2022, the Hamilton County Sheriff’s Department informed him that he must register as a lifetime sex offender due to Florida's laws.The Hamilton Superior Court granted summary judgment in favor of the State, finding that Peters was required to register for life in Indiana because of his obligation in Florida. The Indiana Court of Appeals affirmed this decision, interpreting the relevant statute to require registration in Indiana for individuals with out-of-state registration obligations, regardless of the source of those obligations.The Indiana Supreme Court reviewed the case and held that the statute applies to individuals with out-of-state registration obligations, regardless of the source. However, the court found that Peters is not currently required to register in Florida because his registration obligations there lapsed when he moved out of the state. Consequently, the court concluded that Peters does not need to register as a sex offender in Indiana. The Indiana Supreme Court reversed the trial court's decision and remanded the case for entry of summary judgment in favor of Peters. View "Peters v. Quakenbush" on Justia Law

McKinley Kelly, at sixteen, was convicted of murdering three young adults. The trial court vacated one conviction and sentenced him to 110 years in prison. Kelly's appeals and petitions for post-conviction relief were unsuccessful. The Court of Appeals allowed him to file a successive petition for post-conviction relief, focusing on new scientific understandings of adolescent brain development, arguing for a resentencing or a more lenient sentence.The Lake Superior Court denied Kelly's petition, and the Court of Appeals affirmed. Kelly then appealed to the Indiana Supreme Court, which granted transfer to address procedural and substantive issues related to juvenile sentencing. The Indiana Supreme Court affirmed the post-conviction court's decision, concluding that the post-conviction court appropriately allowed Kelly to amend his successive petition without requiring appellate screening.The Indiana Supreme Court held that the state and federal constitutional provisions cited by Kelly did not mandate a more lenient sentence. The court found that Kelly's sentence was not inappropriate given the nature of his offenses and his character. The court emphasized that the legislature had recently amended the sentence modification statute to allow juvenile offenders to have their sentences reexamined after twenty years, providing an opportunity for review based on rehabilitative progress.The court concluded that Kelly's new evidence on adolescent brain development was cumulative and unlikely to produce a different result. The court also rejected Kelly's claims under the Indiana Constitution, finding that his sentence did not violate provisions related to cruel and unusual punishment, proportionality, reformation, unnecessary rigor, or equal protection. Similarly, the court found no violation of the Eighth or Fourteenth Amendments of the U.S. Constitution. Finally, the court declined to revise Kelly's sentence under Appellate Rule 7(B), finding it appropriate in light of the nature of his offenses and his character. View "Kelly v. State of Indiana" on Justia Law

Chelsea L. Crossland was convicted by a jury of murder and neglect of a dependent resulting in death, specifically her five-year-old son, Christian Crossland. Christian was subjected to severe neglect and abuse after moving in with his mother in January 2022. He was confined to a bedroom closet, deprived of food, and beaten. On the night of his death, Christian was found emaciated and injured. Crossland delayed calling for help and provided conflicting accounts of the events leading to his death. An autopsy revealed that Christian died from blunt-force injuries, starvation, and dehydration.The Jay Circuit Court denied Crossland's motion for a change of venue due to pretrial publicity and her motion to strike several jurors for cause. The jury found Crossland guilty, and the trial court imposed a life-without-parole (LWOP) sentence based on the jury's recommendation. Crossland appealed directly to the Indiana Supreme Court, arguing that she was denied an impartial jury and the right to present a complete defense.The Indiana Supreme Court reviewed the case and found no evidence that the jury was unable to render an impartial verdict despite pretrial publicity. The court also determined that the trial court did not abuse its discretion in denying Crossland's motion for a change of venue or in its handling of juror challenges. Additionally, the court held that the exclusion of certain impeachment evidence did not violate Crossland's constitutional rights and that any error in excluding this evidence was harmless given the overwhelming evidence of her guilt.The Indiana Supreme Court affirmed the trial court's judgment, upholding Crossland's conviction and LWOP sentence. View "Crossland v. State" on Justia Law

A fifteen-year-old, J.Q.R., sold fentanyl-laced pills to two classmates, B.H. and R.J., resulting in R.J.'s death from an overdose. During the investigation, police discovered evidence implicating J.Q.R.'s father in illegal drug activities. The father waived J.Q.R.'s Miranda rights twice, leading to J.Q.R. making incriminating statements to the police.The Hendricks Superior Court admitted J.Q.R.'s statements into evidence over his objections, arguing that his father had an adverse interest due to his own criminal conduct. The court adjudicated J.Q.R. as a delinquent child. The Indiana Court of Appeals affirmed the trial court's decision.The Indiana Supreme Court reviewed the case and held that an adverse interest may arise if an adult stands to personally benefit from waiving a child's rights to the child's detriment. The court found that the State failed to prove beyond a reasonable doubt that the father had no adverse interest when he waived J.Q.R.'s rights, given the evidence of the father's own drug activities. Therefore, the trial court erred in admitting J.Q.R.'s statements.However, the Indiana Supreme Court concluded that the error was harmless because independent evidence, such as text messages, established that J.Q.R. knew the pills contained fentanyl. Consequently, the court affirmed the trial court's adjudication of J.Q.R. as a delinquent child. View "J.Q.R. v. State" on Justia Law

Zachariah Konkle, a ride operator at a traveling carnival, was involved in an altercation with Michael Steele, a game operator, at the Jackson County Fair. The conflict arose after Konkle learned that a game operator had mocked a child with special needs. Konkle, initially attacking the wrong person, later confronted Steele. During the fight, Steele, who had pre-existing heart conditions, was tackled by Konkle, who then hit Steele multiple times and compressed his chest. Steele subsequently died from mechanical asphyxiation complicated by his heart conditions.The Jackson Circuit Court charged Konkle with murder. During the trial, the State invoked the eggshell skull doctrine to argue that Konkle was responsible for Steele's death despite Steele's pre-existing conditions. The jury found Konkle guilty of voluntary manslaughter, and he was sentenced to thirty-four years in prison. Konkle appealed, arguing prosecutorial misconduct, insufficient evidence of a knowing killing, and an inappropriate sentence.The Indiana Court of Appeals reversed the conviction, citing prosecutorial misconduct due to the State's use of the eggshell skull doctrine and fundamental error. However, the Indiana Supreme Court granted transfer, vacating the appellate decision. The Supreme Court held that Konkle did not waive his prosecutorial misconduct claim and found no misconduct, as the eggshell skull doctrine was appropriately applied to causation, not mens rea. The court also found sufficient evidence to support the conviction, noting Konkle's actions and intent during the altercation. Finally, the court upheld the sentence, considering the nature of the offense and Konkle's character, including his criminal history and lack of remorse. The Indiana Supreme Court affirmed Konkle's conviction and sentence. View "Konkle v. State" on Justia Law

Antonio Turner, a student, was studying at a classmate's home when Dequan Briscoe, the classmate's jealous love interest, threatened to attack him. Turner, sensing danger, retrieved his handgun from his car. As he was returning to the house, an unfamiliar car sped towards him. Turner, unable to see inside the car due to its darkly tinted windows, fired four shots, wounding Briscoe, who was indeed aiming a gun at Turner.The Marion Superior Court, after a bench trial, convicted Turner of battery by means of a deadly weapon. The magistrate judge acknowledged that Turner’s actions were necessary to avoid being shot but found that it was objectively unreasonable for Turner to fire at a car he couldn’t see into, thus rejecting Turner’s self-defense claim.The Indiana Supreme Court reviewed the case and vacated Turner’s conviction. The court held that Indiana’s self-defense statute justifies the use of force when it is necessary for protection, even if the necessity is only fully apparent in hindsight. The court concluded that Turner’s shooting was justified because it was necessary to protect himself from an imminent threat, and the force used was proportional to the threat. The court emphasized that the self-defense statute does not require a person to be reasonable in their belief if the belief turns out to be correct. View "Turner v. State" on Justia Law

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

Stevie Bradley was accused of multiple felonies, including attempted murder and domestic battery, after a violent incident with his girlfriend, A.R. Bradley demanded A.R. call another man, and when no one answered, he assaulted her. The violence continued as he drove through rural St. Joseph County, eventually threatening her with a machete. A.R. fled to a nearby home, but Bradley recaptured her, further assaulting her before she managed to escape again. The State charged Bradley with several offenses, and he requested a speedy trial.The St. Joseph Superior Court initially set Bradley's trial within the seventy-day window required by Criminal Rule 4(B). However, the court later ordered a competency evaluation for Bradley, vacating the original trial date. After Bradley was deemed competent, the court reset the trial date beyond the seventy-day period, leading Bradley to file multiple motions for discharge, arguing that his right to a speedy trial was violated. The trial court denied these motions, and Bradley was convicted on all charges except strangulation.The Indiana Court of Appeals vacated Bradley's convictions, ruling that the trial court erred by resetting the seventy-day period instead of merely tolling it during the competency evaluation. The court found no justification for scheduling the trial beyond the original deadline. The State petitioned for transfer, which the Indiana Supreme Court granted.The Indiana Supreme Court held that a trial court’s sua sponte order for a competency evaluation does not reset the Criminal Rule 4(B) period but merely tolls it. However, the court also held that Bradley waived his right to discharge by failing to properly notify the trial court of its scheduling error. Consequently, the Indiana Supreme Court affirmed the trial court's judgment. View "Bradley v. State of Indiana" on Justia Law