Justia Indiana Supreme Court Opinion Summaries

The Supreme Court granted transfer in this case to eliminate a residual double jeopardy violation not addressed by the court of appeals, holding that one of Defendant's remaining convictions must be reduced to a lesser included offense to eliminate the violation.Defendant was convicted of possession of cocaine, enhanced to a level four felony; possession of a narcotic drug, enhanced to a level five felony; and unlawful possession of a firearm by a serious violent felon and adjudicated a habitual offender. On appeal, Defendant argued that his conviction for firearm possession and the enhancements applied to the drug-related counts violated double jeopardy principles because they were based on the same evidence - his possession of a single firearm. The court of appeals affirmed Defendant's drug-related convictions but reversed and vacated the conviction and sentence for the firearm possession conviction. The Supreme Court held that because Defendant's two drug-related convictions were enhanced based on the same evidence of his possession of a single firearm, Defendant's conviction on possession of a narcotic drug must be remanded for entry of judgment as a level six felony. View "Springfield v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court granting Defendant's motion to suppress statements he made during an interrogation as inadmissible in his criminal trial, holding that there was substantial, probative evidence that Defendant was in custody at the time of the interrogation.Two police officers interrogated Defendant in a secured area at a police station without providing him with required Miranda warnings. In granting Defendant's motion to suppress, the trial court determined that the environment in which Defendant was interrogated was a "police setting." The Supreme Court affirmed, holding that the totality of the circumstances supported the trial court's conclusion that the interrogation was custodial. View "State v. Ruiz" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to modify his sentence, holding that Defendant needed the prosecutor's consent to modification before the court could modify his sentence, and because Defendant did not have that consent, his motion was properly denied.Defendant pled guilty to a Class C felony and two Class D felonies and was sentenced to eight years for the Class C felony and two years for each of the Class D felonies. After he was released on parole Defendant filed a motion to modify his sentence on the Class C felony, arguing that the terms of his sentenced placed an unnecessary burden on him as he strived to contribute positively to the community. The trial court denied the motion. The Supreme Court affirmed, holding that because Defendant was a "violent criminal," his motion to modify was governed by subsection (k), and because Defendant filed his motion more than one year after he was sentenced, he needed, but did not have, the prosecutor's consent to modification before the court could modify his sentence. View "Barber v. State" on Justia Law

The Supreme Court reversed the post-conviction court's order denying Appellant's motion to correct error and remanded this matter for further proceedings, holding that a post-conviction court abuses its discretion when it denies a party's legitimate request to make an offer of proof.Appellant was convicted of murder. When seeking post-conviction relief Appellant found himself sharing a holding cell with a man who provided information that, if true, would exonerate Appellant. Appellant's attorney attempted to secure the man's testimony, but obtaining the testimony was challenging. Appellant's counsel eventually sought leave from the court to get the testimony, but the post-conviction court refused to hear any argument from the attorney, even denying her the opportunity to make an offer of proof. After the court closed the evidence and Appellant's counsel attempted to make her case and develop a record for appeal, the court silenced her with threats of contempt. The Supreme Court reversed the post-conviction court's order denying Appellant's motion to correct error, holding that the post-conviction court abused its discretion by denying counsel the opportunity to make an offer of proof. View "Bedolla v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of dealing in a narcotic drug and resisting law enforcement, holding that the trial court did not commit fundamental error by allowing the State to present evidence of Defendant's post-arrest, pre-Miranda silence during trial.The court of appeals affirmed Defendant's conviction conviction, concluding that there was no error in using Defendant's post-arrest, pre-Miranda silence as substantive evidence against him during trial and that, even if there was error, it was not fundamental. The Supreme Court granted transfer and held (1) Defendant opened the door to the State's response that included comments about Defendant's post-arrest, pre-Miranda silence; and (2) even if the trial court erred in admitting the State's evidence and argument about Defendant's silence, the error was not fundamental for the reasons articulated in Owens v. State, 937 N.E.2d 880 (Ind. Ct. App. 2010). View "Kelly v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court revoking Defendant's community corrections placement for possessing obscene matter, holding that the evidence was insufficient to revoke Defendant's probation for possession of obscene matter.When community corrections officers performed a compliance check at Defendant's home they found a cell phone containing pictures of Defendant, as well as pictures of a naked woman and videos with a man and woman engaging in sexual intercourse. The community corrections portion of Defendant's sentence was revoked. On appeal, Defendant argued that because the trial court expressly stated that not all parts of the obscene matter definition were met, the evidence was insufficient to support revocation of his probation. The Supreme Court reversed, holding that reversal was necessary because the trial court made factual findings that negated one part of the statutory definition required to prove the violation. View "Bennett v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony neglect of a dependent resulting in her death, holding that the trial court did not abuse its discretion in admitting evidence at trial that Defendant had, on prior occasions, used a pillow to muffle his infant daughter's crying.On appeal, Defendant argued that the evidence of prior pillow incidents was inadmissible under Ind. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the State may introduce other-bad-acts evidence to show lack of accident only when the State has reliable assurance that an accident defense will be raised or after the defendant places the accident at issue on trial; (2) in the instant case, because the State was reliably assured that Defendant would raise an accident defense, it could properly introduce the Rule 404(b) evidence; and (3) there was no abuse of discretion in admitting that evidence because the evidence's prejudicial effect did not outweigh its probative value. View "Fairbanks v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony resisting, holding that the challenged instruction in this case potentially misled the jury as an incorrect statement of law but that the jury charge, as a whole, cured the instructional defect.Specifically, the Court held (1) Defendant did not invite the alleged instructional error; (2) the challenged instruction misstated the mens rea and threatened to mislead the jury, and therefore, the use of the instruction is disapproved of going forward; but (3) the jury charge provided adequate instructions on the correct statutory elements and standard of proof, and the instructional defect was harmless. The Court then summarily affirmed Defendant’s convictions for felony battery and misdemeanor resisting, holding that Defendant failed to explain how instructional error affected his felony battery and misdemeanor resisting convictions. View "Batchelor v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt.Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt. View "Zanders v. State" on Justia Law

The Supreme Court reversed the judgment of the lower courts denying Appellant’s petition for post-conviction relief on the basis that his attorney provided deficient performance that prejudiced him, holding that counsel rendered ineffective assistance to Appellant by failing to properly advise him about the immigration consequences of a misdemeanor guilty plea.Appellant pleaded guilty to stealing less than twenty dollars of merchandise from Walmart without realizing that his guilty plea made him a deportable felon under federal immigration law. Appellant sought post-conviction relief, alleging ineffective assistance of counsel. The lower courts denied relief. The Supreme Court reversed, holding (1) Appellant’s attorney rendered constitutionally deficient performance as a matter of law by independently marking “N/A” next to the citizenship advisement on the standard advisement of rights from before inquiring into Appellant’s citizenship status; and (2) counsel’s deficient performance prejudiced Appellant. View "Bobadilla v. State" on Justia Law