Justia Indiana Supreme Court Opinion Summaries

The Supreme Court held that evidence obtained after a search and seizure was obtained in violation of the Fourth Amendment and that the trial court erred in denying Defendant’s motion to suppress the evidence obtained as a result of the search and seizure. The trial court denied the motion to suppress, concluding that law enforcement officers had reasonable suspicion to approach and question Defendant after they received a call that someone of Defendant’s description had a handgun on him. The Supreme Court reversed, holding that the intrusion by the police was not reasonable in this case. View "Pinner v. State" on Justia Law

Fifteen years after the Supreme Court affirmed Appellant’s conviction for murder, Appellant filed an amended petition for post-conviction relief, alleging that trial counsel rendered ineffective assistance. The post-conviction court denied relief on the merits. The Supreme Court reversed, holding that, in viewing the evidence without certain inadmissible hearsay statements, Appellant established grounds for relief by a preponderance of the evidence. Specifically, the Court held that counsel’s errors, which allowed the jury to consider the only evidence that identified Appellant as the shooter in determining his guilt or innocence, were sufficient to undermine confidence in the verdict rendered in this case. View "Humphrey v. State" on Justia Law

The Supreme Court held that the “third-party doctrine,” which provides that police are not required to obtain a search warrant to gather information an individual has voluntarily relinquished to a third party, applies as to historical cell-site location information (CSLI). Defendant appealed his convictions on four robbery-related counts, arguing that the State violated his Federal and State Constitutional rights by obtaining historical cell-site location information (CSLI) from his cell-phone service provider and that a detective improperly testified as an expert witness regarding the CSLI. The Supreme Court affirmed, holding (1) under the Fourth Amendment, Defendant had no reasonable expectation of privacy in his cell-phone provider’s historical CSLI; (2) the Indiana Constitution does not prohibit police from taking reasonable actions like obtaining minimally intrusive historical CSLI from a service provider to prevent a criminal suspect from striking again; and (3) the detective sponsoring the CSLI at trial properly testified as a skilled witness. View "Zanders v. State" on Justia Law

Defendant appealed his convictions for two counts of murder for which the trial court imposed consecutive life without parole sentences. The Supreme Court affirmed, holding (1) the evidence was sufficient to sustain the murder convictions; (2) the trial court properly found that the State proved the I.C. 35-50-2-9(b)(11) aggravator beyond a reasonable doubt; (3) the trial court did not abuse its discretion in admitting into evidence Defendant’s recorded phone calls made to a special agent, as the phone calls were not protected by Defendant's Sixth Amendment right to counsel; and (4) Indiana’s life without parole statutory sentencing scheme is constitutional. View "Leonard v. State" on Justia Law

Defendant pleaded guilty to Class D felony theft. As part of his plea agreement with the State, Defendant agreed that he would be “precluded from asking for misdemeanor treatment.” At that time, trial courts could convert sentences only at the time of sentencing. In 2012, however, the General Assembly amended Ind. Code 35-50-2-7 by allowing sentences to be converted after they had been entered. In 2015, Defendant filed a petition seeking to convert his Class D felony to a Class A misdemeanor under section 35-50-2-7(d). The trial court granted the petition, vacated Defendant’s felony, and re-entered the conviction as a Class A misdemeanor. The Supreme Court reversed, holding that the legislative amendment did not alter the unambiguous terms of Defendant’s plea agreement, and therefore, the trial court exceeded its authority when it granted Defendant’s petition, circumventing the agreement’s terms. View "State v. Smith" on Justia Law

The State charged Defendant with dealing in marijuana and maintaining a common nuisance. At some point, the State informed Defendant that it had a video recording of a controlled buy between him and a confidential informant (CI). The State offered Defendant’s public defender the opportunity to review the recording but would not allow Defendant himself to see the video. After Defendant unsuccessfully requested a copy of the recording, his counsel filed a motion to compel, arguing that Defendant’s personal review of the video was fundamental to preparing a defense. In response, the State claimed that the informer’s privilege allowed withholding the identity of the CI. The trial court denied the motion to compel. The Supreme Court reversed, holding (1) the State failed to make the threshold showing that the informer’s privilege applied in the first instance because it was unclear whether the video would actually reveal the informant’s identity; and (2) even if the State had made the threshold showing, Defendant carried his burden of proving an exception to the privilege because his review of the video was “relevant and helpful to his defense or [was] necessary for a fair trial.” View "Beville v. State" on Justia Law

Defendant entered a field sobriety checkpoint and was asked if he had been drinking. Defendant admitted that he had. The officer administered some field sobriety tests and ultimately arrested Defendant. Defendant was charged with operating while intoxicated and operating a vehicle with an alcohol concentration of at least .08 but less than .15 grams of alcohol per 210 liters of breath. During trial, Defendant’s counsel objected to the officer’s testimony about him asking Defendant if he had been drinking and Defendant’s response based on a Miranda violation. In response, the State argued that a Miranda warning was not necessary. The trial court then entered an order suppressing any statements made by Defendant, as well as any evidence obtained thereafter. On appeal, the Court of Appeals, dismissed the appeal, ruling that the State had no statutory authority to appeal because Defendant never filed a written motion to suppress and because the order suppressing the evidence was issued during trial. The Supreme Court granted transfer and reversed the trial court’s suppression order, holding (1) the State may appeal from the trial court’s order granting Defendant’s motion to suppress; and (2) Miranda warnings are not required in circumstances such as these, where a defendant is briefly detained at a public sobriety checkpoint. View "State v. Brown" on Justia Law

Defendant pleaded guilty to two counts of attempted murder as class A felonies and two counts of attempted robbery resulting in serious bodily injury also as class A felonies. Defendant was sentenced to 100 years’ imprisonment with sixty years suspended to probation for an aggregate sentence of forty years executed. Defendant later filed a petition for post-convcition relief, arguing that his guilty plea was not entered knowingly, intelligently, and voluntarily, that the plea lacked a factual basis, and that the trial court erred in accepting the plea. The Supreme Court reversed, holding that Petitioner demonstrated by a preponderance of the evidence that the post-conviction court erred in denying his petition for relief because, at the time Petitioner entered the plea, he also professed his innocence. View "Ellis v. State" on Justia Law

Defendant was convicted of two counts of Class B felony burglary and adjudicated a habitual offender. The trial court sentenced Defendant to an aggregate sentence of thirty-three years. Defendant appealed, arguing that his sentence was inappropriate under Indiana Appellate Rule 7(B). The court of appeals affirmed. The Supreme Court granted transfer and revised Defendant’s sentences so that he received an aggregate sentence of sixteen years, holding that an aggregate sentence of thirty-three years was inappropriate in this case. In all other respects the Court summarily affirmed the Court of Appeals’ decision. View "Wampler v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder. Defendant was sentenced to life without parole. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court did not commit fundamental error when it did not find, sua sponte, that Defendant had an intellectual disability, precluding a life without parole sentence, even though Defendant's trial counsel withdrew the petition to determine whether he had the disability; (2) Defendant’s life without parole sentence was proportionate to the offense and thus did not violate Article 1, Section 16 of the Indiana Constitution; and (3) Defendant’s sentence was appropriate pursuant to Indiana Appellate Rule 7(B). View "Shoun v. State" on Justia Law