Justia Indiana Supreme Court Opinion Summaries

The State charged Defendant with two counts of unlawful possession of a firearm by a serious violent felon (SVF) and several other offenses. The SVF charges were based on the State’s allegation that Defendant had previously been convicted of second degree burglary in Ohio. After the trial court concluded that the Ohio statute and Indiana statutes on burglary were not substantially similar in regard to the elements of the offense, the trial court dismissed the two counts charging Defendant as an SVF. Thereafter, the State moved for mistrial on grounds it believed Defendant could not receive a fair trial because during voir dire the State had referred to the now-dismissed SVF courts. The trial court granted the motion. The State subsequently appealed the dismissal of the SVF counts. The court of appeals affirmed. The Supreme Court granted transfer and reversed the trial court, holding that the elements of Ohio’s second degree felony burglary statute are substantially similar to the corollary elements of Indiana’s level four felony burglary state, and therefore, the trial court erred in dismissing the informations charging Defendant as a serious violent felon. View "State v. Hancock" on Justia Law

Defendant was charged with felony possession. Defendant filed a motion to suppress, arguing that the police violated the Fourth Amendment and Article I, Section 11 of the Indiana Constitution when they opened his car door “to check on [Defendant’s] welfare.” The trial court denied the motion and, after a bench trial, convicted Defendant of misdemeanor possession of cocaine. The court of appeals affirmed, concluding that the police’s act of opening Defendant’s door was constitutionally permissible as a reasonable community caretaking function. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed, holding that the police’s warrantless search of Defendant was constitutionally permissible, as the officer had an objectively reasonable basis to open the door and check on Defendant’s well-being. View "Cruz-Salazar v. State" on Justia Law

Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law

Appellant pled guilty to possession of cocaine as a class D felony. In 2007, Appellant filed a pro se petition for post-conviction relief alleging ineffective assistance of counsel. The court summarily denied Appellant’s petition. In 2015, by counsel, Appellant filed a verified motion for leave to amend his petition for post-conviction relief and a verified motion for relief from the 2007 order that summarily denied his petition for post-conviction relief, arguing, inter alia, that his post-conviction petition was not referred to the State Public Defender and that his lack of education and cognitive deficiencies impacted his ability to represent himself. The post-conviction court determined that it would reinstate Appellant’s 2007 petition for post-conviction relief. The Supreme Court affirmed, holding that because Appellant’s 2007 petition for post-conviction relief was not referred to the State Public Defendant as required by the Post-Conviction Rules, and in light of Petitioner’s educational and cognitive deficiencies, the post-conviction court did not err in granting Appellant’s motion for relief from judgment so that he could seek meaningful post-conviction review. View "State v. Collier" on Justia Law

After a jury trial, Defendant was convicted of murder, murder in the perpetration of criminal deviate conduct, and related crimes. The State sought a sentence of life without parole, but in the penalty phase, the jury was unable to reach a unanimous verdict as to whether the State had proven its charged aggravating circumstance. Nonetheless, the trial court sentenced Defendant to life imprisonment without the possibility of parole on the murder count. The Supreme Court remanded for a revised sentencing order as to the judge’s conclusion that life imprisonment was the appropriate sentence. On remand, the trial court affirmed the sentence. Defendant appealed, arguing, on grounds not previously raised, that the trial court’s imposition of a life sentence violated the Sixth Amendment because the aggravating factor supporting the sentence was not determined by the trier of fact during the penalty phase. The Supreme Court agreed, holding that the trial court committed reversible error by imposing a sentence of life without parole under the circumstances. In the interests of judicial economy, the Court further exercised its appellate prerogative to sentence Defendant to a term of years. View "Lewis v. State" on Justia Law

After a bench trial, Defendant was found guilty of Class B misdemeanor criminal mischief. After sentencing, the trial court held a separate hearing to determine the amount of restitution Defendant owed. The court ultimately concluded that Defendant owed $932 in restitution and that Defendant had the ability to pay in monthly installments of approximately $80. The restitution was ordered as a condition of Defendant’s probation. Defendant appealed the restitution order, arguing that it exceeded what he was able to pay in violation of Ind. Code 35-38-2-2.3(a)(6). The Supreme Court vacated the ordered restitution, holding that the restitution order was an abuse of discretion because the evidence was insufficient to conclude that Defendant had the ability to pay. View "Bell v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, robbery, and conspiracy to commit robbery. Defendant was sentenced to life imprisonment without possibility of parole. Defendant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) Defendant was not denied due process in discovery; (2) Defendant was not denied his right to a speedy trial; (3) the trial court did not abuse its discretion in denying Defendant’s requests to hire DNA and blood spatter experts at public expense; (4) the trial court did not commit fundamental error by allowing unknown witnesses to remain in the courtroom during opening statements despite a separation order; (5) the trial court did not abuse its discretion by allowing the State’s entomologist to testify; (6) the trial court properly admitted evidence found in Defendant’s van; and (7) sufficient evidence supported Defendant’s convictions. View "Griffith v. State" on Justia Law

Defendant pleaded guilty to one count of child solicitation as a Level 5 felony. The offense carried a sentencing range of one to six years, with three years being the advisory sentence. The trial court sentenced Defendant to the advisory sentence of three years, executed in the Department of Correction. Defendant appealed his sentence. The court of appeals ordered that Defendant be released from incarceration and serve the remainder of his three-year sentence on supervised probation, concluding that his fully-executed sentence was inappropriate under Indiana Appellate Rule 7(B). The Supreme Court granted transfer and affirmed the sentence imposed by the trial court, holding that the sentence imposed by the trial court did not warrant appellate revision and was not inappropriate under Rule 7(B). View "Bess v. State" on Justia Law

D.A. filed a petition for the expungement of several criminal conviction records. The trial court granted the petition and ordered the expungement of certain records related to D.A.’s convictions. Thereafter, Petitioner filed a second petition asking for the expungement of civil forfeiture records. The trial court denied the petition, concluding that the expungment statutes apply to arrests and criminal convictions but not to civil forfeitures. The Supreme Court affirmed the denial of D.A. second expungement petition, holding that Indiana’s expungement statutes do not reach civil forfeiture records. View "D.A. v. State" on Justia Law

Defendant and his wife were on the brink of divorce when Defendant screamed in his wife’s face and spat in her eye. Defendant was found guilty of B-misdemeanor disorderly conduct for knowingly or intentionally engaging in fighting and/or tumultuous conduct with his wife. Defendant appealed, arguing that the disorderly conduct statute requires both a public disturbance and a physical altercation and that the State failed to prove those elements. The Supreme Court affirmed, holding (1) the disorderly conduct statute’s “fighting” subsection does not contain a public disturbance element but does require a physical altercation; and (2) Defendant’s intentional spitting provided sufficient evidence of a physical altercation. View "Day v. State" on Justia Law