Justia Indiana Supreme Court Opinion Summaries

In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

In 2013, Defendant was charged with second degree murder for the death of a toddler that occurred in 1977. During a bench trial, the court admitted into evidence an autopsy report. The autopsy was performed by a pathologist who was unavailable to testify at trial. In addition to the autopsy report, the State called a forensic pathologist to testify regarding his independent opinion of the child’s death and injuries based on the autopsy report. The trial court found Defendant guilty of second degree murder. Defendant was sentenced to life imprisonment under the relevant sentencing statutes in 1977. The Supreme Court affirmed, holding (1) because the autopsy report was not testimonial, Defendant’s confrontation right was not violated when the report was admitted into evidence or when the surrogate pathologist testified regarding the information detailed in the autopsy report; (2) the delay between the murder of the child and Defendant’s prosecution did not violate Defendant’s due process rights; and (3) even if the trial court erred at sentencing by taking into consideration the current sentencing scheme that was inapplicable in this case, the error was harmless. View "Ackerman v. State" on Justia Law

Defendant was arrested for suspected murder. During Defendant’s pre-interrogation with his lawyer, police officers and a prosecutor eavesdropped as Defendant and his attorney discussed the location of evidence and defense trial strategy. Defendant was charged with murder. The officers involved in the investigation invoked the Fifth Amendment in response to all questions related to the eavesdropping, thus preventing Defendant and the court from learning the identity of the eavesdroppers and what they had overhead. Before trial, the trial court ordered blanket suppression of trial testimony from any witness who pleaded the Fifth. The State appealed the blanket suppression ruling. The Court of Appeals reversed the pretrial blanket suppression. The Supreme Court granted transfer, thereby vacating the opinion of the Court of Appeals, holding that prospectively imposing blanket suppression of all testimony from witnesses pleading the Fifth Amendment is inappropriate because a presumption of prejudice, rebuttable only by proof beyond a reasonable doubt, adequately protects Defendant from prejudice caused by the officers’ eavesdropping and their assertion of the Fifth Amendment privilege. Remanded for a determination as to whether the State has proven beyond a reasonable doubt an independent source for each presumptively tainted witness’s testimony without implicating the witness’s Fifth Amendment privilege and without derogating Defendant’s right of confrontation. View "State v. Taylor" on Justia Law

Defendant was convicted of class B felony dealing in methamphetamine (by delivery) (Counts I and II), one count of class B felony dealing in methamphetamine (by manufacture) (Count III), and one count of class D felony possession of precursors with intent to manufacture methamphetamine (Count IV). The sentences for Counts III and IV were imposed to run concurrently with each other but consecutive to the sentences on Counts I and II. Defendant received an aggregate sentence of thirty-two years. The Court of Appeals affirmed. The Supreme Court reversed Defendant’s sentences on Counts III and IV to run concurrently with his sentences on Counts I and II, for an aggregate sentence of sixteen years, holding that, under the particular circumstances of this case, the aggregate sentence of thirty-two years was inappropriate. View "Eckelbarger v. State" on Justia Law

After a jury trial, Defendant was convicted of murdering four people. Defendant was sentenced to life without parole for each of the four counts of murder, with the sentences to run consecutively. On appeal, Defendant challenged the sufficiency of the evidence to convict him of four murders. This appeal came directly to the Supreme Court because a sentence of life without parole was imposed. The Supreme Court affirmed the judgment of the trial court, holding that the State presented ample evidence that Defendant committed the four murders. View "Sallee v. State" on Justia Law

After a jury trial, Defendants, a married couple, were each convicted of involuntary manslaughter. After they were sentenced, Defendants filed a motion to correct error seeking a mistrial based on one juror’s affidavit describing the conduct of an alternate juror during the jury’s deliberations. The trial court denied the motion. The Court of Appeals affirmed the convictions. The Supreme Court granted transfer, consolidated the cases, and reversed the convictions, holding (1) the juror’s affidavit established that the alternate juror’s participation in jury deliberations was an external influence that pertained to the case, which showings resulted in a presumption of prejudice to Defendants; and (2) the State did not rebut the presumption by showing that the jury was nonetheless impartial, and therefore, a new trial is required. Remanded. View "Wahl v. State" on Justia Law

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