Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained after Defendant was stopped for speeding, holding that there was reasonable suspicion for a traffic stop under the circumstances.At issue was whether there was reasonable suspicion for the traffic stop where the police officer’s calibrated radar indicated that an oncoming vehicle was speeding and the officer verified the radar speed exceeded the posted speed limit but failed to document the excessive speed. The trial court denied Defendant’s motion to suppress on the basis that the officer’s stop of Defendant was based upon his observation that a traffic infraction was being committed. The Supreme Court affirmed, holding that the traffic stop passed muster under both the United States and Indiana Constitutions. View "Marshall v. State" on Justia Law

At issue in this case was whether to extend the holding in Tumulty v. State, 666 N.E.2d 394 (Ind. 1996) that a adult criminal defendant cannot challenge the validity of his guilty plea on direct appeal to an agreed delinquency adjudication. The Supreme Court held in this case that before Juvenile may pursue an appeal he must first seek relief from the trial court under Trial Rule 60(B).Specifically, the Supreme Court held (1) juveniles cannot immediately challenge on direct appeal any errors concerning their agreed adjudication, but because juveniles are not eligible for post-conviction relief, before pursuing their constitutional right to appeal, they must first assert any claims of error concerning their agreed judgment in a request for post-judgment relief filed with the juvenile court; and (2) juveniles who seek that relief in post-judgment proceedings have a statutory right to counsel under Ind. Code 31-32. View "J.W. v. State" on Justia Law

Finding this to be a rare and exceptional criminal case, the Supreme Court reduced Defendant’s sentence pursuant to Appellate Rule 7(B), holding that the sentence imposed was inappropriate in light of Defendant’s offenses and character.Defendant pled guilty to multiple drug charges and admitted to being a habitual substance offender. The trial court sentenced Defendant to an aggregate sentence of thirty years to be served in the Indiana Department of Correction. The court of appeals affirmed. The Supreme Court granted Defendant’s petition to transfer and reduced Defendant’s sentence to the mandatory minimum of twenty-three years with the time remaining to be served in community corrections, holding that this was an exceptional case and that Defendant’s sentence was inappropriate given Defendant’s character and offenses committed. View "Livingston v. State" on Justia Law

The Supreme Court affirmed the order of the trial court granting Defendant’s petition for specialized driving privileges, holding that the proper venue for seeking relief when the petitioner “forfeits” driving privileges for life following a felony conviction for driving while suspended is the trial court in the petitioner’s county of residence.Petitioner, a resident of Adams County, was subject to a driver’s license suspension that was a lifetime forfeiture resulting from a felony conviction for driving while suspended as a habitual traffic violator. Petitioner petitioned the Adams Superior Court for specialized driving privileges (DSP), seeking relief that that suspension and two other suspensions. The superior court granted the SDP petition. The court of appeals reversed and remanded, holding that where the Noble Superior Court ordered the lifetime forfeiture, Petitioner was required to petition that court separately for SDP. The Supreme Court reversed, holding the lifetime forfeiture in this case was an administrative suspension rather than a court-ordered suspension, and therefore, Petitioner was required to seek relief in his county of residence rather than in the court that ordered the suspension. View "State v. Reinhart" on Justia Law

The Supreme Court affirmed Defendant’s conviction of murder and felony murder but remanded this matter for a more specific sentencing statement consistent with the dictates of Harrison v. State, 644 N.E.2d 1243, 1262 (Ind. 1995), holding that the sentencing statement did not meet the requirements of Harrison.Defendant pled guilty to the murder of Asenath Arnold and to felony murder for the death of Gary Henderson at the hands of Defendant’s accomplice. Defendant was sentenced to life without parole of the murder charge. The Supreme Court affirmed the convictions and sentence but remanded the matter for a new sentencing statement, holding (1) Defendant’s Miranda rights were not violated; (2) there was sufficient evidence to support the aggravating circumstance that made Defendant eligible for a life without parole sentence; (3) Defendant’s sentence of life with parole was appropriate; but (4) the sentencing statement did not comply with the dictates of Harrison. View "Schuler v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment finding Defendant guilty but mentally ill (GBMI), holding that the evidence led only to the conclusion that Defendant was insane when the crime was committed.Defendant was charged with murder. Defendant invoked the insanity defense and waived her right to a trial by jury. During the bench trial, three mental health experts testified that Defendant was legally insane at the time of the murder and could not appreciate the wrongfulness of her actions. The trial court rejected Defendant’s insanity defense and found Defendant guilty of GBMI, relying on evidence of Defendant’s demeanor in rendering its verdict. The court of appeals reversed, concluding that because of Defendant’s history of mental illness and the unanimous expert opinion, the demeanor evidence had no probative value. The Supreme Court vacated the court of appeals’ opinion and affirmed, holding (1) the fact-finder may discredit expert testimony and rely instead on other probative evidence from which to infer Defendant’s sanity; and (2) evidence of Defendant’s demeanor, taken together with the flaws in expert opinion testimony and the absence of a well-documented history of mental illness, supported the trial court’s rejection of Defendant’s insanity defense. View "Barcroft v. State" on Justia Law

The Supreme Court affirmed the decision of the post-conviction court denying Appellant’s petition for post-conviction relief alleging that his trial and appellate counsel were ineffective, holding that, although counsel made some mistakes, counsel’s performance was not deficient.Appellant was convicted of murdering two children and arson. The convictions were affirmed on appeal. Thereafter, Appellant sought post-conviction relief, alleging multiple instances of ineffective assistance by trial and appellate counsel. The trial court denied the petition. The Supreme Court affirmed, holding (1) counsel’s mistakes did not rise to the level of deficient performance pursuant to Strickland v. Washington, 466 U.S. 668 (1984); and (2) further, Appellant had not demonstrated that there was a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. View "Weisheit v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of four counts of felony child molesting, holding that the attenuation doctrine can apply under the Indiana Constitution and that Defendant’s statements to law enforcement constituted admissible evidence against him.Defendant moved to suppress evidence obtained from an FBI search and subsequent police interviews, alleging that he had been illegally detained and searched. The trial court suppressed evidence obtained from searching Defendant’s computer and electronic equipment, finding that Defendant’s consent to the search was invalid but denied suppression of Defendant’s statements to law enforcement officers, concluding that they were sufficiently attenuated from the illegal search. The court of appeals reversed Defendant’s convictions, holding that the trial court erred in admitting Defendant’s confessions to the officers, ultimately rejecting the attenuation doctrine for Indiana. The Supreme Court vacated the Court of Appeals opinion and affirmed, holding (1) the Indiana Constitution embraces the attenuation doctrine; and (2) Defendant’s statements to law enforcement were sufficiently attenuated from the illegal search so as to be purged from the original taint and were thus admissible at trial. View "Wright v. State" on Justia Law

The Supreme Court held that the requirement set forth in Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), that an advisement of rights be given prior to police obtaining consent to a search from a person in custody does not extend to drug recognition exams (DRE).At issue was whether police are required to advise a person in custody of his or her right to consult with counsel before obtaining consent to perform the DRE exam. The Court of Appeals concluded that without a Pirtle warning, evidence obtained through a DRE is inadmissible. The Supreme Court disagreed, holding that an advisement is not necessary before police can obtain a person’s valid consent to a DRE. View "Dycus v. State" on Justia Law

At issue was what, if any, ability a trial court has to resentence a criminal defendant on felonies underlying a criminal gang enhancement, see Ind. Code 35-50-2-15, when an appellate court has reversed that enhancement and remanded to the trial court.Defendant was found guilty by a jury of committing several criminal offenses in connection with a criminal gang. In applying the criminal gang enhancement statute, the trial court increased Defendant’s overall sentence by thirty years. The Court of Appeals reversed the enhancement. The State and Defendant disputed here the extent of the trial court’s sentencing authority on remand. The Supreme Court held that the criminal gang enhancement statute unambiguously increases the punishment for all the felonies that underlie the enhancement and that vacating such an enhancement disturbs the punishment originally imposed. Therefore, when an appellate court reverses a criminal gang enhancement, on remand, the trial court must resentence a defendant on all surviving underlying felonies. View "Jackson v. State" on Justia Law