Justia Indiana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions, rendered after a jury trial, for committing various meth-related crimes with a drug-free-zone enhancement. The court of appeals reversed the drug-free=zone enhancement and remanded for resentencing, ruling that the evidence was insufficient that a child was “reasonably expected” to be presented at the park where Defendant’s crimes occurred because schools were in session and the park lacked fixtures like trees, benches, and playgrounds. The Supreme Court granted transfer, thus vacating the opinion of the court of appeals, holding that sufficient evidence allowed the jury to conclude that a minor was reasonably expected to be at the park. View "McAlpin v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment convicting Defendant of two counts of knowing murder, one count of conspiracy to commit arson, and dozens of counts of arson. The trial court sentenced Defendant to life without parole (LWOP) on each of the murder convictions and consecutive terms of years of conspiracy and arson. The Supreme Court rejected Defendant’s issues on appeal and affirmed his convictions and LWOP sentences, holding (1) there was sufficient evidence to support the murder convictions and a statutory aggravator; (2) the trial court did not abuse its discretion when it refused Defendant’s lesser included jury instruction; and (3) Indiana’s LWOP sentencing statute is not unconstitutional. View "Leonard v. State" on Justia Law

Defendant pleaded guilty to one count of Class A felony child molesting. During the plea hearing and at sentencing, the prosecutor, the defense counsel, and the trial court agreed that the statutory sentencing range for Defendant’s sentence was thirty to fifty years. Defendant was sentenced to a term of forty years. However, the statutory sentencing range for Defendant’s crime was twenty to fifty years. On appeal, Defendant argued that the trial court’s sentence was based on a mistaken understanding of the minimum sentence. The court of appeals affirmed Defendant’s sentence. The Supreme Court granted transfer and remanded the case to the trial court for resentencing, holding that, under the circumstances of this case, remand was appropriate. View "McGuire v. State" on Justia Law

Defendant was charged with felony attempted murder and felony aggravated battery. The trial judge adjudged Defendant guilty but mentally ill on both counts. Defendant appealed, arguing in part that the State did not present sufficient evidence that he had the specific intent to kill, as required for attempt murder. The court of appeals reversed Defendant’s attempted murder conviction and remanded for a new trial. The State sought transfer. The Supreme Court granted transfer and reversed Defendant’s conviction for attempted murder, holding that a remand was required for the trial court to reconsider the case under the correct legal standard to the existing evidence. View "Miller v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of Class A misdemeanor possession of a handgun with a license, holding that the State’s detention and search of Defendant was unreasonable under Ind. Const. art. I, 11.The court of appeals affirmed Defendant’s conviction, concluding that Defendant’s behavior in evading police in a high crime area was sufficient to give rise to a reasonable suspicion that crime was afoot, especially where the officers believed Defendant was a truant. The Supreme Court vacated the court of appeals’ decision, holding that the police’s investigatory stop, detention, and search of Defendant violated Defendant’s constitutional rights because, although Defendant’s actions were “suspicious,” at the time police moved to detain Defendant, police did not have a reasonable suspicion that he had engaged in or was about to engage in any criminal conduct. View "Jacobs v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of bestiality. On appeal, Defendant argued that the trial court abused its discretion when it admitted evidence of his admissions of guilt, in violation of the corpus delicti rule. The Court of Appeals reversed, concluding that the State was required to prove penetration of the dog’s sex organ by a male sex organ before it could admit Defendant’s statement into evidence. The Supreme Court granted transfer, thus vacating the court of appeals opinion, holding that the State presented independent evidence that provided an inference that Defendant committed bestiality, and therefore, the trial court properly found that the corpus delicti rule was satisfied and admitted Defendant’s confessions into evidence. View "Shinnock v. State" on Justia Law

Defendant carried a handgun as she battered a law enforcement officer and resisted law enforcement. Defendant was not charged with a firearm-related offense, but nonetheless, the State introduced her gun into evidence at trial. Defendant was found guilty of felony battery against a public safety official and resisting law enforcement. Defendant challenged the gun’s admission at trial. The Supreme Court affirmed, holding (1) res gestate did not survive the adoption of Indiana’s Rules of Evidence in 1994; and (2) under the Rules of Evidence, the trial court did not abuse its discretion admitting Defendant’s gun into evidence because the gun was relevant to Defendant’s aggressiveness, and the danger of unfair prejudice did not substantially outweigh its probative value. View "Snow v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for battery against a public safety official and resisting law enforcement, holding (1) as the Supreme Court held in Snow v. State, __ N.E. 3d __ (Ind. 2017), the trial court did not abuse its discretion in admitting into evidence the gun of Defendant’s girlfriend, who was also convicted of the same offenses; and (2) because Defendant failed to seek a separate trial or a limiting instruction he waived any argument that the gun’s admission denied him a fair trial, and there was no fundamental error in the trial court’s decision not to give a limiting instruction sua sponte. View "Harris v. State" on Justia Law

When Defendant was stopped for a traffic violation, Defendant agreed to take a chemical test at a nearby police station. Defendant did not blow hard enough during the test, prompting the machine to print an “insufficient sample” warning. The law enforcement officer determined that Defendant had refused to take the test, which resulted in the suspension of Defendant’s driving privileges. The Supreme Court reversed, holding that the procedures promulgated by the Indiana State Department of Toxicology required the officer to administer a second test because there was no factual basis for the trooper’s determination that Defendant refused the chemical test. View "Hurley v. State" on Justia Law

Indiana appellate courts reviewing the sufficiency of the evidence must apply the same deferential standard of review to video evidence as to other evidence unless the video evidence indisputably contradicts the trial court’s findings. The Supreme Court affirmed Defendant’s convictions for resisting law enforcement and battery to a law enforcement animal as class A misdemeanors, holding that the video evidence presented at trial did not indisputably contradict the testimony of five police officers, and there was other evidence that sufficiently established the elements of the crimes. The Supreme Court’s holding supplemented its standard of review for video evidence to add a narrow failsafe to prevent impermissible reweighing by appellate courts when reviewing video evidence. View "Love v. State" on Justia Law