Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of criminal confinement and battery. Defendant appealed, arguing that his convictions violated the prohibition against double jeopardy under the Indiana Constitution and common law and seeking sentence review. The Supreme Court vacated Defendant’s conviction for battery and its concurrent three year sentence but affirmed Defendant’s conviction and eight year sentence for criminal confinement, holding (1) Defendant’s two convictions do not violate the common law but do violate the Double Jeopardy Clause of the Indiana Constitution under the actual evidence test; and (2) Defendant failed to demonstrate that his sentence is inappropriate for his character and the nature of the offense. View "Hines v. State" on Justia Law

Defendants were charged with murder as accomplices in a shooting. The State brought no other charges, battery or otherwise. During a bench trial, trial court found that Defendants intended a group beating of the victim but that there was insufficient evidence that they knew a member of their group would shoot the victim. Consequently, the trial court dismissed the murder charge, instead returning a verdict of attempted aggravated battery for planning the beating as a lesser included offense to the murder charge. The Supreme Court reversed, holding (1) attempted aggravated battery by beating was not just a lesser offense than the charged murder by shooting but a completely different offense, based on a completely different “means used” than alleged in the charging informations, and the complete factual divergence here deprived Defendants of “fair notice” of the charge of which they were eventually convicted; and (2) convicting Defendants based on a critical operative fact the State never pleaded constituted fundamental error. Remanded with instructions to enter judgments of acquittal. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of molesting his three young granddaughters. Defendant appealed, arguing that he was entitled to separate trials on the allegations of each individual victim. The Court of Appeals reversed and remanded for new and separate trials, concluding that Defendant was entitled to severance under Ind. Code 35-34-1-11(a). The Supreme Court granted the State’s petition to transfer, thereby vacating the opinion below, and affirmed, holding that Defendant’s abuse of girls in this care was sufficiently connected, and therefore, Defendant was not entitled to new and separate trials. Remanded for the purpose of resentencing on one count. View "Pierce v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and robbery. Defendant was sentenced to life imprisonment without parole for the murder conviction. The Supreme Court affirmed, holding (1) the evidence was sufficient for a reasonable jury to conclude that Defendant committed the offense of robbery; (2) the evidence was sufficient to prove the charged statutory predicate for the sentence of life imprisonment without parole; (3) the trial court did not err by admitting evidence regarding Defendant’s attempt to commit suicide two days after police questioned him about the murder; (4) the trial court did not err in allowing testimony over objection regarding Defendant’s appearance the day after the murder; and (5) Defendant’s sentence of life imprisonment without parole was appropriate. View "Stephenson v. State" on Justia Law

In 2000, Appellant was diagnosed with paranoid schizophrenia. In 2004, while unprovoked, Appellant fired a shotgun several times at multiple vehicles, including a police cruiser. The jury returned verdicts of guilty but mentally ill on four counts of Class A felony attempted murder. Appellant was sentenced to an aggregate sentence of 120 years. The court of appeals reversed Appellant’s convictions, concluding that (1) jury clearly erred in rejecting Appellant’s insanity defense, and (2) the admission of evidence regarding Appellant’s post-arrest silence and request for counsel, and the prosecution’s closing arguments relying on those instances as evidence of sanity, violated Appellant’s constitutional due process rights. The Supreme Court granted the State’s petition to transfer, thereby vacating the Court of Appeals opinion, and affirmed the the jury's verdict finding Appellant guilty but mentally ill, holding (1) there was sufficient evidence for a jury to draw a reasonable inference that Defendant was able to appreciate the wrongfulness of his conduct at the time of the offense; (2) there was no due process violation; and (3) Appellant’s sentence was appropriate. View "Myers v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder. Defendant appealed, arguing, among other things, that the trial court erred in refusing his proposed final jury instruction regarding the presumption of innocence. The Court of Appeals affirmed. The Supreme Court granted transfer in order to state precisely what jury instructions a criminal defendant is entitled to receive regarding the presumption of innocence and held (1) it is the right of every criminal defendant to receive the following jury instruction upon request: “The presumption of innocence continues in favor of the defendant throughout the trial. You should fit the evidence to the presumption that the defendant is innocent if you can reasonably do so[ ]”; and (2) the trial court’s failure in this case to use this precise language was not error because the jury instructions adequately encompassed these principles. View "McCowan v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony murder and murder. Defendant was sentenced to sixty-five years for the felony murder and life without parole for the murder. Defendant appealed, asserting that there was insufficient evidence for his convictions and that the incredible dubiosity rule should be applied because no reasonable jury could have found him guilty beyond a reasonable doubt given the inconsistent testimony among three of the State’s primary witnesses. The Supreme Court affirmed Defendant’s convictions and sentence, holding that the evidence was sufficient for a reasonable jury to find Defendant guilty beyond a reasonable doubt for both murders. View "Moore v. State" on Justia Law

The State filed a complaint against Defendant seeking forfeiture of her 1996 Buick Century automobile under the provisions of the Civil Forfeiture Statute, which provides in relevant part that a vehicle may be seized if it is used or is intended for use by the person in possession of it to facilitate the transportation of stolen property. On cross-motions for summary judgment the trial court deemed the vehicle forfeited and awarded the vehicle to the Indianapolis Metropolitan Police Department. The Supreme Court reversed, holding that the State was not entitled to forfeiture of the vehicle because it failed to demonstrate that Defendant was “in possession” of the vehicle as contemplated by the Civil Forfeiture Statute. View "Sargent v. State" on Justia Law

After a bench trial, Defendant was found guilty of criminal trespass as a class A misdemeanor in violation of Ind. Code 35-43-2-2(a)(4) and was sentenced to 365 days in jail. Defendant appealed, challenging the sufficiency of the evidence to support his conviction. The Court of Appeals affirmed. The Supreme Court granted transfer, thereby vacating the Court of Appeals opinion, and reversed the trial court’s judgment, holding that the evidence in this case was insufficient to sustain Defendant’s conviction for Class A misdemeanor criminal trespass. View "Willis v. State" on Justia Law

Defendant was found guilty of patronizing a prostitute. Defendant appealed, arguing that he had raised the entrapment defense by showing police inducement and that the State failed to offer any evidence of Defendant’s predisposition to commit the offense. The Court of Appeals agreed with Defendant and reversed. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and affirmed the trial court, holding (1) Defendant’s entrapment defense failed because a reasonable trier of fact could have found the State proved beyond a reasonable doubt that the police did not induce Defendant; and (2) therefore, the Court did not need to address the question of Defendant’s predisposition to commit the crime. View "Griesemer v. State" on Justia Law