Justia Indiana Supreme Court Opinion Summaries

Defendant was charged with twelve counts of various sex offenses. The charges arose from allegations made by three young girls. While Defendant was in jail awaiting his guilty plea hearing, he wrote an “intimidating and coercive” letter to the mother of one of the child victims. As a result of this letter, Defendant was charged with felony attempted obstruction of justice. The trial court found Defendant guilty of the charge and sentenced him to 600 days. The Supreme Court affirmed Defendant’s conviction and sentence for attempted obstruction of justice, holding (1) sufficient evidence supported the conviction; and (2) the trial court failed to properly consider Defendant’s participation in various program while incarcerated as a mitigating factor, but the error was harmless. View "McElfresh v. State" on Justia Law

Defendant was convicted of C-felony “corrupt business influence,” the formal name of the Indiana Racketeer Influenced and Corrupt Organizations (RICO) Act, for his involvement in three armed robberies during the course of a month. Defendant appealed, arguing that the State presented insufficient evidence to support his conviction for corrupt business influence because the State failed to prove that his actions posed a threat of “continued” criminal activity. The court of appeals agreed and reversed Defendant’s corrupt business influence conviction. The Supreme Court granted transfer and affirmed Defendant’s conviction for corrupt business influence, holding (1) continuity is not required for a corrupt business influence conviction, but continuity is relevant to whether the incidents were “not isolated,” which is an element of the definition; and (2) in this case, there was sufficient evidence that Defendant’s crimes were not isolated. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, attempted murder, felony murder, and related crimes. The trial court imposed life without parole for the murder conviction and a term of years for the remaining convictions. Defendant appealed, arguing that the trial court’s remark to the jury regarding cell tower towers and sites deprived him of a fair trial by vouching for the credibility of the State’s evidence and thereby discrediting his alibi defense. The Supreme Court affirmed the convictions and sentences, holding that the judge’s comment did not amount to fundamental error requiring reversal of Defendant’s convictions and a new trial. View "Blaize v. State" on Justia Law

Police impounded Defendant’s car from a parking lot because he was arrested for driving while suspended, the car’s windshield and bumper were damaged, and the registered owner was not present. When police inventoried the car, they found a handgun inside. Defendant was ultimately convicted of carrying a handgun without a license. The Supreme Court reversed Defendant’s handgun conviction, holding that, as required by Fair v. State, the State failed to prove an established departmental procedure or regulation that authorized the discretionary impound under the community-caretaking function, and therefore, the State failed to prove that the impoundment was reasonable. View "Wilford v. State" on Justia Law

In 2002, Defendant was adjudicated delinquent in Texas for a sex offense. Defendant was required to register in Texas as a sex offender until 2014. In 2006, Indiana amended the Sex Offender Registry Act’s definition of sex offender to include “a person who is required to register as a sex offender in any jurisdiction.” In 2009, Defendant moved to Indiana but did not register as a sex offender. Defendant was charged with failing to register as a sex offender in Indiana. Defendant moved to dismiss the charge, arguing that enforcing the registry requirement would be an ex post violation because his offense occurred before the change to the definition of sex offender took effect. The trial court denied the motion. The Supreme Court affirmed, holding that Defendant has failed to show the amended definition retroactively punished him, and therefore, there was no ex post facto law violation. View "Tyson v. State" on Justia Law

In 1992, Defendant was convicted in Michigan of a sex offense. Michigan and Indiana later enacted laws requiring convicted sex offenders to register with local law enforcement. Pursuant to Michigan’s Sex Offender Registration Act, Defendant was required to register as a sex offender for twenty-five years upon his release from prison in 1999. In 2006, the Indiana General Assembly amended the definition of sex offender in Indiana’s Act to include “a person who is required to register as a sex offender in any jurisdiction.” In 2012, Defendant moved to Indiana, where he was required to register for the remainder of his Michigan registration period. Defendant petitioned for removal from the registry, arguing that enforcing the requirement would be an ex post facto violation as applied to him because, at the time he committed the underlying offense, neither Michigan nor Indiana had adopted Sex Offender Registration Acts. The trial court granted Defendant’s petition. The Supreme Court reversed, holding that the 2006 definitional amendment to the Michigan Act does not impose a punitive burden on Defendant beyond that which Michigan has already imposed, and therefore, there is not ex post facto violation. View "State v. Zerbe" on Justia Law

Defendant was charged with battering J.M., his girlfriend. While she was being treated for her injuries, J.M. told a paramedic and forensic nurse that Defendant was the source of her injuries. J.M. was reported missing shortly after the assault and failed to appear for scheduled depositions. The State later provided notice of intent to introduce J.M.'s statement identifying Defendant as her attacker through the testimony of the paramedic and forensic nurse. The trial court granted the motion. After a bench trial, Defendant was convicted of C-felony battery and A-misdemeanor domestic battery. Defendant appealed, arguing that J.M.’s statements were testimonial hearsay admitted in violation of his confrontation rights. The Supreme Court affirmed, holding that J.M.’s hearsay statements were non-testimonial and, therefore, were properly admitted into evidence. View "Ward v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of Class B felony burglary, among other crimes. The burglary convictions resulted from breaking and entering into an old farmhouse. The Supreme Court reversed the two convictions for burglary as Class B felonies and remanded for the entry of two replacement convictions for burglary as Class C felonies, holding that the jury instruction’s expansion of the statutory definition of a “dwelling” for purposes of Class B felony burglary was misleading and invaded the province of the jury and was therefore erroneous. Remanded for resentencing. View "Keller v. State" on Justia Law

Defendant was lawfully placed under arrest for driving without a valid driver’s license. Before the police officer placed Defendant in his police cruiser, he conducted a pat-down search of Defendant’s clothing to check for weapons. The officer discovered a pill container in Defendant’s pocket, opened the container, and found a single narcotic pill for which Defendant did not have a valid prescription. Defendant was charged with driving without a license and possession of a controlled substance. Defendant moved to suppress the evidence of the pill container’s contents, arguing that the officer’s opening of the pill contained was an unreasonable search. The trial court denied Defendant’s motion to suppress. The Supreme Court affirmed, holding that the opening of the pill container was within the scope of a search incident to a lawful arrest and reasonable under the Indiana Constitution. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of the murder of James Allen and the attempted murder of Gerald Beamon. Defendant appealed, arguing that the trial court erred in admitting Beamon’s testimony that Allen told Beamon he had shot Defendant the day before Allen’s murder. The court of appeals affirmed, concluding that the admission of the hearsay evidence was erroneous but harmless. The Supreme Court granted transfer on this issue, vacating that portion of the opinion below, and affirmed the admission of the hearsay testimony, holding that the statements fell within the hearsay exception of Ind. R. Evid. 804(b)(3), and therefore, the trial court did not err in admitting the challenged testimony on that basis. View "Beasley v. State" on Justia Law