Justia Indiana Supreme Court Opinion Summaries

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

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