Justia Indiana Supreme Court Opinion Summaries

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

Joseph Corcoran was convicted of four murders by an Allen County jury, and the judge sentenced him to death as recommended by the jury. Corcoran has been involved in extensive litigation over the past 25 years, including multiple decisions from the Indiana Supreme Court and the United States Supreme Court, regarding the constitutionality of his execution. Corcoran has expressed his desire to accept his conviction and sentence, stating that he does not wish to pursue further legal challenges.The Allen Superior Court initially sentenced Corcoran to death, and the Indiana Supreme Court remanded for resentencing due to the consideration of non-statutory aggravating factors. Upon resentencing, the death sentence was reimposed and affirmed by the Indiana Supreme Court. Corcoran chose not to pursue post-conviction relief, leading to competency proceedings initiated by the State Public Defender, who argued that Corcoran was incompetent to waive post-conviction remedies. The trial court and the Indiana Supreme Court found Corcoran competent. Corcoran later filed an untimely petition for post-conviction relief, which was dismissed.The Indiana Supreme Court reviewed the case and denied the State Public Defender's motions to file successive petitions for post-conviction relief and to stay the execution. The court held that Corcoran is competent to waive post-conviction remedies and that the State Public Defender lacks standing to file the petitions without Corcoran's authorization. Additionally, the court found no reasonable possibility that Corcoran is entitled to relief, as the claims presented were procedurally defaulted and previously addressed. The court concluded that Corcoran has a rational understanding of his execution and the reasons for it, and thus, denied the motions for a stay of execution. View "Corcoran v. State" on Justia Law

Russell Finnegan was held in indirect contempt by a judge for sending vulgar and offensive communications to the court. Finnegan's counsel requested a mental health evaluation under Indiana Code section 35-36-2-2(b), which the trial court denied. The Court of Appeals reversed this decision, finding the denial to be an error. The appellate court held that the statutory procedures for asserting an insanity defense in criminal proceedings should apply to indirect criminal contempt actions.The Pulaski Circuit Court initially found Finnegan in contempt for his communications, which included vulgar language and disrespectful remarks directed at the judge. During the contempt hearing, Finnegan's counsel mentioned that he was undergoing mental health evaluations in an unrelated criminal case and requested a continuance for these evaluations. The trial court denied the continuance and did not act on the request to appoint mental health experts. Finnegan was found in contempt and sentenced to 170 days in jail. The Court of Appeals reversed this decision, ruling that Finnegan was entitled to the same statutory protections as other criminal defendants, including the right to a mental health evaluation.The Indiana Supreme Court reviewed the case and vacated the Court of Appeals' opinion. The Supreme Court held that the statutory procedures for asserting an insanity defense in criminal cases do not apply to indirect criminal contempt actions because such actions are not considered "criminal cases" under the relevant statute. The court emphasized that indirect contempt is a sui generis proceeding, distinct from both criminal and civil cases. The court affirmed the trial court's decision, concluding that the insanity defense statutes do not apply to indirect contempt proceedings. View "Finnegan v. State" on Justia Law

Mathew Cramer was convicted of murdering and dismembering Shane Nguyen. Cramer, who lived in a storage unit, accepted a ride from Nguyen, and after a series of interactions, Cramer decided to kill Nguyen. He lured Nguyen to the storage unit, choked him, and then further assaulted him until he was dead. Cramer and an accomplice then dismembered Nguyen's body, placed the parts in trash bags, and attempted to dispose of them. They were apprehended after a police chase.The Allen Superior Court found Cramer guilty of murder, abuse of a corpse, and resisting law enforcement. The jury recommended a sentence of life imprisonment without parole (LWOP), which the trial court imposed. Cramer appealed, requesting a revision of his sentence to a term of years under Indiana Appellate Rule 7(B), arguing that his actions and character did not warrant LWOP.The Indiana Supreme Court reviewed the case and upheld the trial court's decision. The court found that the nature of Cramer’s offense was extremely brutal, involving premeditated murder and grotesque dismemberment of the victim. Additionally, Cramer’s criminal history and lack of mitigating factors supported the LWOP sentence. The court concluded that Cramer’s sentence was appropriate given the heinous nature of the crime and his character, and thus declined to revise it. View "Cramer v. State" on Justia Law

Four appellants sought post-conviction relief in Elkhart County, Indiana, alleging systemic police and prosecutorial misconduct that led to wrongful convictions. They argued that the judge, who had recused herself in a similar prior case involving Andrew Royer, should also recuse herself from their cases due to similar concerns about impartiality. The judge had previously recused herself in Royer's case because she had characterized Royer's attorney's comments as "defamatory" and had worked with many of the witnesses Royer intended to call, raising questions about her impartiality.In the lower courts, the Elkhart Circuit Court judge denied the appellants' motions for recusal, reasoning that her prior employment as a deputy prosecutor did not necessitate recusal and that her comments in Royer's case were misunderstood. The Indiana Court of Appeals affirmed the trial court's decisions, agreeing with the judge's reasoning.The Indiana Supreme Court reviewed the case and concluded that the judge's prior decision to recuse in Royer's case should have compelled her to recuse in these cases as well. The Court held that an objective observer, aware of the judge's prior recusal and the similar concerns raised in these cases, would reasonably question her impartiality. The Court emphasized that the judge's entanglement with the evidence had only deepened, and there was no change in circumstances that would eliminate the concerns leading to her initial recusal.The Indiana Supreme Court reversed the trial court's orders denying the motions for recusal and remanded the cases with instructions to grant the motions, ensuring that the judge recuses herself from these proceedings. View "Seabolt v. State" on Justia Law

In June 2021, Cohen Hancz-Barron was living with his on-and-off girlfriend, Sarah Zent, and her three young children in Fort Wayne, Indiana. On the morning of June 2, Hancz-Barron drove away in a neighbor's truck, and Sarah and her children were later found dead in their home. The victims had been stabbed multiple times, with wounds severing their jugular veins and carotid arteries. Hancz-Barron quickly became the primary suspect, and he was arrested later that day in Lafayette, Indiana. The State charged Hancz-Barron with four counts of murder and sought a sentence of life without the possibility of parole.At trial, the State presented photographic, DNA, video, and physical evidence, as well as testimony from family members, friends, law enforcement, a forensic pathologist, and a forensic biologist. The jury found Hancz-Barron guilty as charged. At sentencing, the State incorporated the evidence presented during the guilt phase to support the two statutory aggravators. The defense presented mitigating evidence through testimony from both Hancz-Barron’s mother and a forensic psychologist who examined Hancz-Barron after his arrest. The jury found the State proved both statutory aggravators beyond a reasonable doubt, found the aggravating circumstances outweighed the mitigating circumstances, and recommended “a sentence of life imprisonment without parole.” The trial court then found “more than sufficient evidence to support” the jury’s decision, and sentenced Hancz-Barron to four consecutive life sentences.In the Indiana Supreme Court, Hancz-Barron challenged the sufficiency of evidence to sustain his convictions, the trial court’s decision allowing the State to recall a witness, and his sentence on both statutory and constitutional grounds. The court rejected each challenge and affirmed the lower court's decision. The court held that sufficient evidence supported Hancz-Barron’s convictions and that the trial court did not abuse its discretion in allowing the State to recall a witness. The court also held that it could not review the jury’s weighing of aggravating and mitigating circumstances, Hancz-Barron had not shown that his sentence was inappropriate, and his sentence was not unconstitutional. View "Hancz-Barron v. State" on Justia Law