Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of stalking, holding that a charge of stalking may be supported by conduct that is continuous in nature, even if it is a single episode.The statutory definition of stalking requires repeated or continuing harassment. Defendant's actions that led to his conviction involved following a college student's vehicle for more than two hours as she attempted to evade him. Even though Defendant's actions took place over the course of less than three hours the court of appeals affirmed Defendant's conviction and sentence, concluding that Defendant's actions amounted to repeated or continuing harassment or impermissible contact. The Supreme Court affirmed after clarifying that a charge of stalking may be supported by conduct that is purely continuous in nature, holding that Defendant's conduct met the statutory definition of "continuing" harassment, thereby supporting his conviction for stalking. View "Falls v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of two counts of operating a vehicle while intoxicated, holding that the trial court abused its discretion in refusing to conduct a hearing regarding the possible bias of a juror who, after being selected to serve on the jury but before being sworn, submitted a note informing the trial court that one of her family members had been killed by a drunk driver.Defense counsel requested an opportunity to explore the juror's potential bias, but the trial court did not allow further questioning. The Supreme Court reversed Defendant's convictions and remanded the proceedings for a new trial, holding that the information conveyed by the juror to the trial court before the jury was sworn should have resulted in a hearing to determine whether Defendant could properly have challenged the juror's service for cause. View "Easler v. State" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing in part Defendant's convictions, holding that that the court of appeals' effort to correct a double jeopardy violation misconstrued Paquette v. State, 101 N.E.3d 234 (Ind. 2018) (Paquette I).The trial court convicted Defendant of three counts of resisting law enforcement by fleeing in a vehicle causing death, a Level 3 felony, operating a vehicle with methamphetamine in his blood causing serious bodily injury, a Level 4 felony, and two Level 6 felonies. In Defendant's first appeal, the Supreme Court held, among other things, that the resisting law enforcement statute does not contemplate multiple convictions when multiple victims were killed as a result of a single incident of resisting. After the case was remanded, the court of appeals reversed in part. The Supreme Court held that the court of appeals misconstrued Paquette I by vacating the Level 3 felony conviction instead of one of the three Level 4 felony convictions. The Court then remanded for the trial court to impose judgment for one count of Level 3 felony resisting law enforcement causing death, two counts of Level 4 felony operating causing death, and one count of Level 6 felony operating causing serious bodily injury and to sentence accordingly. View "Paquette v. State" on Justia Law

The Supreme Court vacated the decision of the court of appeals revising Defendant's sentence for three counts of Class A felony child molesting and revised the sentences to the original terms set by the trial court, holding that the sentence imposed by the court of appeals was wholly inadequate under the circumstances.The trial court sentenced Defendant to consecutive terms of thirty years on each count of his conviction for child molesting for an executed sentence of ninety years, with twenty years suspended. The court of appeals revised Defendant's sentence to concurrent thirty-year terms, with no time suspended, on all three counts. The Supreme Court granted vacated the court of appeals' decision and revised Defendant's sentences to the original consecutive thirty-year temps, with thirty years suspended, for an executed sentence of sixty years, holding that a thirty-year aggregate sentence was inadequate under the circumstances. View "Faith v. State" on Justia Law

In this post-conviction proceeding, the Supreme Court held that a post-conviction petition that addresses only the proceedings on remand from a federal court's grant of a new trial is not a "second" or "successive" petition under Ind. Post-Conviction Rule 1(12) and that such a petition may proceed without the prior authorization of the Supreme Court or the court of appeals.Defendant filed a petition for post-conviction relief alleging ineffective assistance of counsel in his criminal proceedings. The post-conviction court and court of appeals denied the petition. Defendant then filed a petition for writ of habeas corpus, which the federal district court denied. The federal court of appeals vacated the district court's judgment and remanded with instructions to issue a writ of habeas corpus unless the State granted Defendant a new appeal. Defendant subsequently filed a second direct appeal, which the court of appeals denied. Defendant filed another petition for post-conviction relief, alleging that his appellate attorney failed properly to argue the issues in his new direct appeal. The trial court dismissed the petition as an unauthorized successive petition under Rule 1(12). The Supreme Court remanded for further proceedings, holding that because the petition addressed only the grounds arising from the second appeal, it may proceed without prior appellate authorization. View "Shaw v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and other crimes and sentencing him to life without parole, holding that each of Defendant's contentions on appeal were without merit.Specifically, the Court held (1) sufficient evidence supported Defendant's conviction for auto theft, and the Court needn't address Defendant's felony-murder challenge because the trial court merged those verdicts with his murder convictions; (2) any error in the trial court's admonishments to the jurors each time they were separated wasn't fundamental; (3) the trial court did not violate Defendant's Confrontation Clause rights by admitting post-crime text messages of Defendant's co-conspirator because the messages weren't testimonial; (4) any error in the decision of the trial court to read a withdrawn accomplice liability instruction was harmless; and (5) the trial court did not manifestly abuse its discretion when it sentenced Defendant to life without parole. View "Cardosi v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant's petition to modify her Class B felony sentence, holding that the trial court had no discretion to modify Defendant's sentence because Defendant's plea agreement called for a fixed sentence.In today's companion case, Rodriguez v. State, __ N.E.3d __ (Ind. 2019), the Supreme Court determined that the legislature's amendments to Ind. Code 35-38-1-17 did not signify a shift from the long-standing precedent of Pannarale v. State, 638 N.E.2d 1247 (Ind. 1994), in which the Court found that trial courts are bound by the terms of a plea agreement and may only modify a sentence in a way that would have been authorized at the time of sentencing. In the instant case, the trial court granted Defendant's petition to modify her sentence, which was imposed in accordance with the terms of a plea agreement. The Supreme Court reversed, holding that because Defendant's plea agreement called for a fixed sentence the trial court was bound by these terms and had no discretion to modify Defendant's sentence. View "State v. Stafford" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's petition to modify his sentence on the grounds that it was not authorized to modify the sentence imposed under Defendant's fixed-term plea agreement, holding that the decades-old rule that courts may modify a sentence only if a new sentence would not have violated the terms of the valid plea agreement had the new sentence been originally imposed remained undisturbed.Defendant petitioned to modify his sentence, arguing that recent changes to the modification statute supported the court's ability to modify his sentence. The State opposed the petition, arguing that courts have no power to modify a sentence once the court has accepted a binding stipulated plea agreement. The trial court agreed and denied Defendant's motion to modify his sentence. The court of appeals reversed, concluding that modification of Defendant's sentence was permissible. The Supreme Court granted transfer and affirmed the judgment of the trial court, holding that the legislature's amendments did not alter the settled law of Pannarale v. State, 638 N.E.2d 1247 (Ind. 1994), and its progeny, and therefore, the trial court properly found that it had no discretion to modify Defendant's sentence because it was bound by the terms of the valid plea agreement. View "Rodriguez v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of Class A misdemeanor domestic battery, holding that Defendant did not validly waive his right to a jury trial.In the underlying proceedings Defendant signed two advisement of rights forms. By the time he signed the second form the deadline to request a jury trial had passed. Neither form advised Defendant of the timeline to file a demand for a jury trial and that his failure to file a demand within that period would result in the waiver of his right. Further, the first advisement of rights did not inform Defendant that his demand for a jury trial had to be in writing. The Supreme Court held that Defendant did not validly waive his right to a jury trial. Because the evidence was sufficient to support the conviction, the Court noted that the State was free to retry Defendant. View "Dadouch v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court ordering state police officers to turn over to federal authorities a shipped box containing U.S. currency wrapped in multiple layers of sealed packaging that bore the odor of narcotics, holding that the totality of the circumstances established the requisite probable cause to believe the money was proceeds of drug trafficking.The shipped box in this case displayed hallmarks of parcels containing drugs and drug money. The officer sought and was granted a warrant authorizing a search of the package and seizure of proceeds of drug trafficking. Officers proceeded to open the box, and a canine alerted that the money contained therein, and not just the packaging surrounding it, contained the odor of narcotics. The officers then seized the cash and obtained a court order to turn it over to federal authorities. Appellant, the individual who shipped the parcel, argued on appeal that the seizure exceeded the scope of the warrant. The Supreme Court affirmed, holding (1) all the circumstances supplied a basis for probable cause to believe the cash was proceeds of drug trafficking; and (2) therefore, the seizure was lawful, and the trial court properly made its order transferring the property to the federal government. View "Hodges v. State" on Justia Law