Justia Indiana Supreme Court Opinion Summaries

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

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