Justia Indiana Supreme Court Opinion Summaries

Appellant was convicted of conspiracy to deal in cocaine as a class B felony and sentenced to an executed term of sixteen years. After an unsuccessful appeal, Appellant filed a pro se petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court denied relief. Still acting pro se, Appellant attempted to appeal the denial of his petition, but despite his “best efforts,” the appeal went awry. The court of appeals dismissed the appeal. The Supreme Court granted transfer, thereby vacating the court of appeals’ order. After full briefing on the merits, the Supreme Court affirmed the judgment of the post-conviction court, holding that the post-conviction court did not err in denying Appellant’s claim that counsel rendered ineffective assistance. View "Hollowell v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of attempted murder, burglary resulting in serious bodily injury, aggravated battery, and battery. Defendant later filed a petition for post-conviction relief, alleging ineffective assistance of trial counsel, in part, for counsel’s failure to object to a supplemental jury instruction on the definition of “intentionally” that was given after deliberations had begun. The post-conviction court denied relief. The Supreme Court affirmed, holding that the instruction represented a correct statement of the law, and therefore, trial counsel in this case did not render ineffective assistance in failing to object to the instruction. View "Campbell v. State" on Justia Law

After a jury trial, Defendant was convicted on multiple counts of child molesting, child solicitation, and possession of child pornography. Defendant sought appellate review of the trial court’s denial of his motions to strike three prospective jurors for cause. The central issue before the Supreme Court was Indiana’s exhaustion rule, under which parties may seek appellate review of for-cause challenges to prospective jurors only if they have exhausted their peremptory challenges. The Supreme Court affirmed Defendant’s conviction, holding (1) parties satisfy the exhaustion rule the moment they use their final peremptory challenge, regardless of whom they strike; (2) where parties comply with the exhaustion rule, appellate courts may review denial of any motion to strike for cause, regardless of whether a challenged juror actually served on the jury; and (3) Defendant preserved appellate review of three for-cause challenges, but the trial court did not abuse its discretion by denying all of them. View "Oswalt v. State" on Justia Law

While responding to a report of dogs fighting in Defendant’s backyard, law enforcement officers entered Defendant’s house to retrieve one bloody and aggressive dog and to ensure no one was injured. Once inside the home, the officers found marijuana plants. Based on the evidence found in Defendant’s home, Defendant was charged with five Class D felonies. Defendant moved to suppress the evidence, arguing that the search violated his rights under the federal and state Constitutions. The trial court denied Defendant’s motion and found him guilty of all charges. The court of appeals affirmed, concluding that exigent circumstances justified the officers’ warrantless entry into Defendant’s home. The Supreme Court granted transfer and reversed the trial court, holding that the officers’ entry into Defendant’s home was unreasonable and therefore impermissible under the Indiana Constitution, and therefore, the trial court erred by admitting the evidence recovered from Defendant’s home. View "Carpenter v. State" on Justia Law

Plaintiffs sued Defendants for fraudulently failing to disclose defects in a home on a sales disclosure form. The trial court awarded compensatory damages but not fees, costs, or exemplary damages under the Crime Victims Relief Act (CVRA). Plaintiffs moved to correct error, asserting that the court was required to award fees and costs because they had established the CVRA predicate crime of deception. The trial court denied the motion. The Supreme Court affirmed, holding that the trial court acted within its discretion in compensating Plaintiffs for their common-law damages but refusing to award attorney fees or exemplary damages under the CVRA, as Plaintiffs’ complaint encompassed multiple alternative theories of liability not limited to the CVRA, and a court need not impose CVRA liability when it believes ordinary tort liability will do. View "Wysocki v. Johnson" on Justia Law

Defendant, a teacher and coach, was charged with two counts of attempted child seduction after communicating with a sixteen-year-old student via an internet site and asking the student to sneak out of her parents house to engage in sexual conduct with him. Citing Ward v. State, Defendant moved to dismiss the charges on grounds that the online solicitation was not aimed at the “immediate commission of a crime.” The trial court denied the motion to dismiss. The court of appeals reversed. The Supreme Court granted transfer and affirmed the trial court, holding that the charges matched the statutory elements and were sufficient to survive a motion to dismiss at this time. View "Corbin v. State" on Justia Law

The State filed a class C felony child molestation charge against Appellant, and 1,291 days elapsed before the beginning of Appellant’s trial. Appellant was found guilty as charged and sentenced to six years executed. Appellant appealed, arguing that he was entitled discharge under Ind. R. Crim. P. 4(C) and that the unduly long delay violated his right to a speedy trial under the United States and Indiana Constitutions. The Supreme Court vacated Appellant’s conviction and ordered him released from incarceration, holding that despite the trial court’s technical compliance with Rule 4(c), the delay between the filing of the charge against Appellant and the beginning of Appellant’s trial violated his right to a speedy trial under the United States and Indiana Constitutions. Remanded. View "Logan v. State" on Justia Law

After a bench trial, Petitioner was convicted of class B felony criminal confinement. Petitioner’s conviction was affirmed on appeal. Petitioner subsequently filed a petition for post-conviction relief, alleging that his trial and appellate counsel provided ineffective assistance. Specifically, Petitioner contended that had counsel presented Long v. State, he would not have been convicted of class B felony confinement or his conviction would have been set aside for insufficient evidence. The post-conviction court agreed with Petitioner and ordered his conviction reduced to a class D felony. The court of appeals affirmed. The Supreme Court reversed, holding that Petitioner mischaracterized Long, and accordingly, Petitioner’s counsels did not render ineffective assistance by failing to present an incorrect interpretation of case law. View "State v. Greene" on Justia Law

Defendant was convicted of dealing cocaine and related offenses. The State subsequently filed civil proceedings seeking forfeiture of Defendant’s car and the cash discovered in a search incident to Defendant’s arrest, alleging that both were connected to Defendant’s dealing. The State sought summary judgment. In response, Defendant filed an affidavit denying that the cash was connected to his dealing. The trial court granted summary judgment in favor of the State for forfeiture of the cash. The court of appeals affirmed, determining that Defendant failed to raise any genuine issue of material fact that would preclude summary judgment. The Supreme Court reversed, holding that Defendant’s competent affidavit contradicted the State’s designated evidence on a material fact and was therefore sufficient to preclude summary judgment. Remanded. View "Hughley v. State" on Justia Law

Appellant was charged with several felony offenses and two misdemeanor offenses arising from a foiled drug sale. Appellant was found guilty as charged. After Appellant was sentenced, a post-conviction court scheduled the matter for a resentencing hearing. Following resentencing, the trial court sentenced Appellant to an aggregate term of thirty-eight years. The Supreme Court vacated Appellant’s conviction and five-year sentence imposed under the handgun enhancement charge, holding that the trial court erred by entering convictions and sentences for both carrying a handgun without a permit and use of a firearm in controlled substance offense as an enhancement based on possession of the same handgun. Remanded. View "Cross v. State" on Justia Law