Justia Indiana Supreme Court Opinion Summaries

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

Police officers asked Defendant to step out of his truck during a traffic stop and made their permission conditional on a pat-down. During the pat-down, the officers discovered marijuana on Defendant’s person. Defendant then admitted he had a pipe in his truck. Defendant was charged with possession of marijuana and possession of paraphernalia. The trial court granted Defendant’s motion to suppress the marijuana and the pipe. The Court of Appeals affirmed on different grounds, concluding that Defendant’s consent to the pat-down was invalid because the choice of being patted down as a condition of exiting the vehicle or else remaining in the vehicle unsearched was inherently coercive and rendered Defendant’s consent involuntary. The Supreme Court reversed, holding (1) it is not inherently coercive for police to give conditional permission to step out of the vehicle, subject to the motorist’s consent to a pat-down; and (2) any extension of the search from Defendant’s initial consent was the product of his subsequent consent and not of improper police conduct. View "State v. Cunningham" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and felony arson resulting in serious bodily injury. The jury recommended the death penalty, and the trial court sentenced Defendant accordingly. The Supreme Court affirmed the convictions and sentence, holding (1) the trial court did not err in excluding a prison administration expert from testifying that Defendant could safely be incarcerated for the remainder of his natural life; (2) there was sufficient evidence to support the convictions; (3) the trial court did not commit reversible error in refusing to excuse twelve jurors for cause; (4) Defendant was not entitled to a mistrial after a juror placed a note in the jury room thanking jurors for their service to the deceased; (5) the district court did not err in refusing to suppress statements Defendant made to police; (6) the trial court did not abuse its discretion in sentencing Defendant to death; and (7) the jury and the trial court properly considered and weighed Defendant’s offered mitigating circumstances. View "Weisheit v. State" on Justia Law

Defendant was charged with four counts of robbery and six counts of criminal confinement, among other charges. The charges arose from four different bank robberies that occurred over the course of a year and a half. The jury returned guilty verdicts on all robbery counts. Defendant appealed, arguing, among other things, that the charge for Class B felony robbery relating to a March 21, 2006 robbery should be dismissed on the grounds that it was filed outside of the statute of limitations period because the statutory concealment-tolling provision under Ind. Code 35-41-4-2(h)(2) was inapplicable in his case. The Supreme Court dismissed the charge stemming from the March 21, 2006 robbery, holding (1) the application of the concealment-tolling provision requires a positive act by the defendant that is calculated to conceal the fact that a crime has been committed; (2) Defendant did not engage in any positive act calculated to conceal the fact that a robbery occurred on March 21, 2006; and (3) because the statute of limitations as to the March 21, 2006 offense was not tolled, the charge should have been dismissed. View "Study v. State" on Justia Law