Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of attempted murder. At Defendant’s trial and during final instructions, the trial court properly instructed the jury on the crime of attempted murder. Although Defendant was not charged as an accomplice to attempted murder, and his attempted murder charge was not explicitly premised on a theory of accomplice liability, the trial court also instructed the jury on accomplice liability. During closing arguments, the State argued both direct liability and accomplice liability theories for the attempted murder. The verdict form also did not distinguish between Defendant’s potential direct liability or accomplice liability for the attempted murder. The jury found Defendant guilty as charged. Defendant appealed, arguing that the trial court erred by not instructing the jury that it must find he had the specific intent to kill when he knowingly or intentionally aided, induced, or caused another person to attempt murder. The Supreme Court reversed the conviction, holding that the trial court committed fundamental error by giving an instruction permitting the jury to convict Defendant of attempted murder as an accomplice without the specific intent to kill. View "Rosales v. State" on Justia Law

Defendant was intoxicated when he crashed his vehicle into a service vehicle, killing the service truck driver. After a trial, Defendant was found guilty of operating a motor vehicle while intoxicated in a manner endangering a person and operating a motor vehicle while intoxicated, but the jury deadlocked on the most serious of Defendant’s charges. Defendant moved for judgment on the verdicts. The trial court denied Defendant’s motion to compel an entry of judgment on the verdicts and permitted the State to retry Defendant on all counts. After a second trial, the jury once again found Defendant guilty of the lesser offenses and also found Defendant guilty of the more serious offenses of causing death when operating a motor vehicle while intoxicated as class B and C felonies. The Supreme Court affirmed the convictions and sentence, holding (1) Defendant’s first deadlock on the most serious of his charges, paired with its finding of guilt as to the lesser offenses, did not equate to an implied acquittal of those more serious offenses; and (2) the prohibition against double jeopardy was not violated when Defendant was retried on the greater offenses upon which the jury was deadlocked. View "Cleary v. State" on Justia Law

After a bench trial, Defendant was found guilty of criminal deviate conduct and criminal confinement, among other offenses. Defendant appealed, arguing, inter alia, that the trial court erred in limiting his cross-examination of a witness concerning the alleged victim’s credibility for truthfulness. The Court of Appeals concluded that the trial court erred in excluding testimony regarding the alleged victim’s truthfulness and vacated Defendant’s conviction for criminal confinement. The Supreme Court granted transfer and affirmed the trial court, holding that the trial court did not abuse its discretion by prohibiting evidence of specific instances of conduct regarding the alleged victim’s truthfulness. View "Jacobs v. State" on Justia Law

Defendant was convicted under Indiana’s public intoxication statute of being intoxicated in a public place and engaging in annoying conduct. Defendant appealed, arguing that the term “annoys” in the public intoxication statute is unconstitutionally vague and that there was insufficient evidence to sustain his conviction. The Supreme Court vacated Defendant’s conviction for misdemeanor public intoxication, holding (1) Indiana’s public intoxication statute is constitutional when a reasonableness standard is applied to the term “annoys”; and (2) in applying this reasonableness standard, there was insufficient evidence to sustain Defendant’s conviction for public intoxication. View "Morgan v. State" on Justia Law

After a jury trial, Defendant was convicted for being a serious violent felon in possession of a firearm. Defendant appealed, arguing, among other things, that the trial court erred by admitting a detective’s testimony that out-of-court witnesses identified Defendant as the suspect. The Supreme Court affirmed, holding (1) the testimony of the detective was inadmissible hearsay, and therefore, trial court abused its discretion by admitting the testimony, but the erroneous admission of the hearsay testimony was harmless; and (2) there was no material variance between the allegations against Defendant and the proof used to convict him. View "Blount v. State" on Justia Law

After a jury trial, Defendant was found guilty of Class A felony dealing in methamphetamine, among other charges, and received an aggregate sentence of forty years. Defendant appealed his sentence under Ind. App. R. 7(B), arguing that his sentence was inappropriate given the nature of the offense and his character. The court of appeals ultimately determined that the sentence was appropriate. The Supreme Court concluded that, given the nature of the offense and the character of the defendant, Defendants’ sentence was inappropriate. Remanded to the trial court to impose a sentence of thirty years for dealing in methamphetamine. View "Parks v. State" on Justia Law

Defendant was charged with Class A felony manufacturing methamphetamine - enhanced from a Class B felony because at least three grams of the drug were at issue. The State relied significantly on a liquid solvent that contained methamphetamine to support the three-gram weight enhancement. A jury found Defendant guilty of the Class A felony methamphetamine offense. Defendant appealed, arguing that the evidence was insufficient to support the three-gram weight enhancement. The Supreme Court affirmed, holding (1) when the State seeks to establish the weight of manufactured methamphetamine based on an intermediate mixture that contains methamphetamine, it must demonstrate how much final product that mixture would have yielded had the defendant finished the manufacturing process; (2) because the State failed to present this evidence, it could not use the intermediate mixture to establish the three-gram weight enhancement for Class A felony manufacturing methamphetamine; but (3) because the record showed that Defendant manufactured additional final product that exceeded the three-gram threshold, the evidence was sufficient to sustain Defendant’s conviction. View "Buelna v. State" on Justia Law

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