Justia Indiana Supreme Court Opinion Summaries

Defendant was a passenger in a vehicle that was stopped for not having a properly displayed license plate. The driver was placed under arrest for driving with a suspended license, and the police requested that Defendant exit the vehicle so an inventory search could be conducted. Upon exiting the vehicle, Defendant informed the police that he had a handgun in his pocket. Defendant was later found guilty of carrying a handgun without a license. Defendant appealed, arguing that the trial court erred in refusing to give his tendered final jury instruction on the defense of necessity. The Supreme Court reversed, holding (1) there was some evidence that warranted giving the defense of necessity instruction; and (2) it was error for the trial court to have refused giving the instruction. View "Hernandez v. State" on Justia Law

The State prosecuted three co-defendants on identical charges in the same trial. The Supreme Court reversed the convictions of two of those three co-defendants and remanded to the trial court with instructions to enter judgments of acquittal. The case involving the third co-defendant, Latoya Lee, was indistinguishable from the cases of her two co-defendants with the exception that she belatedly filed her petition to transfer. The Supreme Court granted Latoya’s petition to transfer and reversed her conviction, holding that there was no reason to treat her differently that her co-defendants, who now stand acquitted. Remanded with instructions to enter a judgment of acquittal. View "Lee v. State" on Justia Law

After a jury trial, Defendant was found guilty of two felony counts of dealing in cocaine. The Court of Appeals affirmed, concluding that a detective’s opinion testimony on witnessing a drug transaction led only to an inference of guilt and was not an opinion of guilt itself in violation of Ind. R. Evid. 704(b). The Supreme Court granted transfer, holding (1) the trial court erred in admitting the detective’s statement, as the statement was an opinion of Defendant’s guilt that violated Rule 704(b); (2) the admission of the guilt opinion testimony, however, was harmless error; and (3) on all other issues, the Court of Appeals is summarily affirmed. View "Williams v. State" on Justia Law

Defendant was charged with possessing, selling and dealing in the chemical compound designated XLR11 and dealing and conspiracy to commit dealing in look-alike substances. Defendant filed a motion to dismiss the charges, claiming that the information failed to reference the Indiana Board of Pharmacy’s Emergency Rule 12-493(E), which criminalized XLR11; the applicable statutory schemes were void for vagueness; and the General Assembly could not delegate to the Pharmacy Board the power to criminalize XLR11. The trial court denied Defendant’s motion. The Supreme Court (1) affirmed the trial court’s denial of Defendant’s motion to dismiss the charges against him under the applicable statutes, holding that there was no constitutional or statutory infirmity to any of the charges; but (2) dismissed the XLR11-related charges, holding that the charging information was inadequate with respect to those charges. Remanded. View "Tiplick v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of murder. The trial court sentenced Defendant to life imprisonment without parole. Defendant sought post-conviction relief and subsequently received a new sentencing hearing. At the conclusion of the hearing, the jury recommended a sentence of life imprisonment without parole, and the trial court sentenced Defendant accordingly. Defendant appealed his sentence, seeking a reduction to a term of years. The Supreme Court affirmed, holding (1) the nature of the offense and the character of Defendant do not present a sufficiently compelling basis to override the decision of the jury and the trial court; and (2) Defendant’s claim that the jury’s weighing of aggravating and mitigating factors was an abuse of discretion was nonjusticiable. View "Helsley v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder. The trial judge sentenced Defendant to death for the murder. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in denying Defendant’s request for a fourth continuance; (2) did not err in refusing to dismiss an entire venire panel or declare a mistrial based on some potential jurors’ exposure to Defendant’s other murder charges; (3) did not abuse its discretion in denying Defendant’s request to ask a case-specific question during voir dire; (4) did not abuse its discretion in denying Defendant’s for-cause juror challenges; and (5) did not abuse its discretion in declining to instruct the jury on voluntary manslaughter. Further, Defendant’s sentence of death was not inappropriate. View "Gibson v. State" on Justia Law

The State charged eighteen-year-old Anthony Sharp, sixteen-year-old Blake Layman, and seventeen-year-old Levi Sparks with felony murder in the perpetration of a burglary. The jury found each defendant guilty as charged. In a consolidated appeal, Layman and Sparks claimed, among other things, that the felony murder statute was incorrectly applied in this case and that their sentences were inappropriate. The Court of Appeals affirmed the convictions but revised the sentences. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion. On transfer, Defendants invited the Supreme Court to revisit and overrule State v. Palmer and instead adopt the view expressed by the dissenting Justices in that case, namely, that a plain reading of the felony murder statute does not authorize the imposition of liability for murder where the defendant’s fellow perpetrator was the person killed. The Supreme Court reversed, holding (1) Palmer and its progeny continue to be valid, but the facts in those cases are significantly different from the facts here; and (2) the evidence was not sufficient to sustain a conviction for felony murder in the perpetration of a burglary. Remanded for further proceedings. View "Layman v. State" on Justia Law

The State charged eighteen-year-old Anthony Sharp, sixteen-year-old Blake Layman, and seventeen-year-old Levi Sparks with felony murder in the perpetration of a burglary. The jury found each defendant guilty as charged. On appeal, Sharp argued that the felony murder statute was incorrectly applied in this case, citing in support of his argument the Court’s opinion in Palmer v. State and arguing that the facts here were distinguishable. The Court of Appeals rejected Sharp’s attempt to distinguish the facts in this case from those in Palmer and ruled that there was no error in the application of the felony-murder statute to the facts of this case. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion. On transfer, Sharp argued that the precedent of Palmer and the application of the felony murder statute were in need of reconsideration. The Supreme Court reversed, holding (1) Palmer and its progeny continue to be valid, but the facts in those cases are significantly different from the facts here; and (2) because the Court reversed the felony murder convictions of both Layman and Sparks, and because Sharp is identically situated, his conviction for felony murder is reversed as well. Remanded for further proceedings. View "Sharp v. State" on Justia Law

After a jury trial, Defendant was convicted of one count each of aggravated battery, criminal confinement by removal, and battery resulting in serious bodily injury. Due to double jeopardy concerns, the trial court entered judgment for only the aggravated battery and criminal confinement counts. The court of appeals affirmed Defendant’s convictions and sentence. The Supreme Court granted transfer and reversed Defendant’s criminal confinement conviction and concurrent sentence, holding that there was insufficient evidence to support Defendant’s conviction for criminal confinement. View "Gibson v. State" on Justia Law

After a jury-waived trial, Defendant was found guilty of robbery and criminal confinement. The trial court used the same evidence, namely, Defendant’s act of being armed with a deadly weapon, to enhance both of his convictions from class C to class B felonies. Defendant appealed, arguing that the two convictions violated Indiana’s constitutional ban on double jeopardy because the force used to support the robbery conviction was coextensive with the force used to support the confinement conviction. The court of appeals affirmed. The Supreme Court affirmed, holding that committing two or more separate offenses each while armed with the same deadly weapon is not within the category of rules precluding the enhancement of each offense based on “the very same behavior.” View "Sistrunk v. State" on Justia Law