Justia Indiana Supreme Court Opinion Summaries

After a second jury trial, Defendant was convicted of child molesting as a class C felony. On appeal, Defendant challenged, among other things, the admission of testimony by a child forensic interviewer who had conducted a forensic interview of the victim that she did not observe any signs that the victim had been coached. Because Defendant did not object to this testimony, Defendant argued that the admission of the testimony was fundamental error. The Court of Appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the disputed testimony was improper, as the testimony constituted impermissible indirect vouching; but (2) the error did not constitute fundamental error. View "Sampson v. State" on Justia Law

After a jury trial, Defendant was convicted of class A felony child molesting. The court of appeals reversed Defendant’s conviction and remanded for a new trial, holding that the trial court abused its discretion in denying Defendant’s motion to compel the victim’s mother to answer a deposition question about an incident in the victim’s past and in excluding from evidence the substance of a phone conversation with the victim’s mother in which she and the victim discussed the incident. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding that the trial court’s alleged errors, even if considered violations of Defendant’s Sixth Amendment right to confrontation, were harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

Defendant pleaded guilty to multiple counts each of class C felony neglect of a dependent and class C felony criminal confinement. The plea agreement left sentencing to the discretion of the trial court but capped Defendant’s sentence at ten years pursuant to Ind. Code 35-50-1-2(c). This section, however, did not actually apply to Defendant. The trial court accepted the plea agreement and sentenced Defendant to ten years pursuant to the perceived statutory cap. Defendant appealed, challenging the trial court’s imposition of the aggregate sentence. The court of appeals reversed Defendant’s sentence, determining, sua sponte, that the erroneous application of section 35-50-1-2(c) rendered the plea agreement void as a matter of law. The Supreme Court granted transfer, thus vacating the decision below, and affirmed the trial court’s acceptance of Defendant’s plea agreement and its imposition of a ten-year sentence, holding that Defendant’s plea agreement was valid and enforceable despite the mistaken application of section 35-50-1-2(c). View "Russell v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary, a class C felony. The Court of Appeals reversed the conviction, finding that the conviction was obtained through the State’s knowing use of perjured testimony. The Supreme Court granted transfer, thus vacating the opinion of the Court of Appeals, and affirmed the conviction, holding (1) Defendant’s due process rights were not implicated by the inconsistent testimony, as the State notified opposing counsel and the court of the conflicting testimony and proactively drew attention to the discrepancies in the testimony throughout the trial, thus permitting the jury to fully function as an informed fact finder; and (2) the incredible dubiosity rule was not applicable to this case. View "Smith v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder and arson. The trial court sentenced Defendant to life imprisonment without the possibility of parole (LWOP). The Supreme Court affirmed, holding (1) the jury’s decision not to find Defendant insane or guilty but mentally ill was not contrary to law; (2) the trial court did not abuse its discretion by admitting testimony about Defendant’s evasiveness during police questioning because it was admissible as lay opinion testimony; and (3) Defendant’s LWOP sentence was not inappropriate under Appellate Rule 7(B) based on the nature of the offense and Defendant’s character. View "Satterfield v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, felony murder, criminal deviate conduct, and resisting law enforcement. The trial judge sentenced Defendant to life imprisonment without the possibility of parole and an additional term of three years for resisting law enforcement. The Supreme Court affirmed the convictions but reversed the sentencing determination, holding (1) the evidence was sufficient to support the conviction for criminal deviate conduct; (2) the trial court’s failure to give a reasonable theory of innocence instruction was not fundamental error; (3) the trial court erred in admitting testimony regarding Defendant’s prior conduct while consuming alcohol, but the error was harmless; and (4) the sentencing order did not contain a personal conclusion by the judge that life without parole was an appropriate punishment, in violation of Harrison v. State and Pittman v. State. Remanded for a revised sentencing order. View "Lewis v. State" on Justia Law

Defendant was living in the residence of an individual who was home home detention under Community Corrections supervision when community corrections officers went into the residence to conduct a warrantless search to ensure Sullivan’s compliance with the conditions of the program. The ensuing search uncovered illegal drugs in the common areas in the residence as well as drugs and drug paraphernalia in Defendant’s private bedroom. Defendant was charged with maintaining a common nuisance and other drug-related offenses. The trial court granted Defendant’s motion to suppress in part, concluding that the Community Corrections officers had consent to search the common areas of the residence but not Defendant’s private bedroom. The Supreme Court reversed, holding that all of the evidence seized from the compliance search was the result of an improper entry and search because the home detention participant had agreed to written conditions of his participation that consented only to searches upon probable cause, which was wholly lacking in this case. Remanded with instructions to grant the motion to suppress in its entirety. View "State v. Vanderkolk" on Justia Law

After a jury trial, Defendant was convicted of a Class C felony battery. Defendant appealed, arguing that he was denied a meaningful opportunity to present a complete defense because the trial court prevented him from presenting testimony of two witnesses that were critical to his claim of self-defense. At trial, Defendant asserted that the testimony was necessary for the purpose of impeaching the victim’s testimony that he had not been the aggressor. The Supreme Court affirmed, holding (1) under Ind. R. Evid. 613(b), extrinsic evidence of a prior inconsistent statement may be admitted before or after a witness is given the opportunity to explain or deny the alleged statement; and (2) in accordance with this interpretation, the trial court properly exercised its discretion in excluding Defendant’s proposed extrinsic evidence. View "Griffith v. State" on Justia Law

After a bench trial, Defendant was found guilty of murder, felony murder, burglary, robbery, and criminal confinement. The trial court sentenced Defendant to life imprisonment for the murder conviction and to a term of years for the burglary and robbery convictions. All sentences were to be served consecutively. Defendant appealed, arguing that the evidence was not sufficient to support his murder conviction. The Supreme Court affirmed, holding that the evidence in the record was sufficient to sustain Defendant’s murder conviction. View "Bell v. State" on Justia Law

After a jury trial, Defendant was found guilty of three counts of murder. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s conviction and death sentence but remanded with instructions to issue a new sentencing order consistent with this opinion, holding (1) the trial court did not err by denying Defendant’s for-cause challenges to certain prospective jurors; (2) the trial court did not err in denying Defendant’s motions for mistrial; (3) the trial court did not abuse its discretion in instructing the jury; (4) the trial court did not err by refusing to allow a witness to answer a question posed by a juror; (5) the State did not commit prosecutorial misconduct during closing arguments in the penalty phase of trial, but the remarks were not so prejudicial to Defendant’s right of fundamental due process as to make a fair trial impossible; (6) Defendant’s death sentence was appropriate; and (7) the trial court exceeded its statutory authority by ordering Defendant’s death sentences to be served consecutively. View "Isom v. State" on Justia Law