Justia Indiana Supreme Court Opinion Summaries

Law enforcement officers arrested Defendant on two counts of theft and seized his clothing, including his shoes, in accordance with their standard booking protocols. After police found what appeared to be blood under the laces of Defendant’s left shoe they subjected the shoe to laboratory testing. The testing revealed the presence of a murder victim’s DNA in that blood. Defendant was charged with murder and theft. Defendant moved to suppress the DNA evidence found on his shoe, arguing that the police should have obtained a separate warrant before subjecting the shoe to testing. The trial court denied the motion, and Defendant was subsequently convicted on all charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, holding that police need not obtain a warrant before subjecting lawfully seized evidence to laboratory testing even if that evidence is unrelated to the crime for which the defendant is in custody. View "Guilmette v. State" on Justia Law

Under the terms of a plea agreement Defendant pleaded guilty to one count of class A felony criminal deviate conduct and class B felony robbery. The trial court sentenced Defendant to a total executed term of forty years. Defendant appealed the trial court’s imposition of his sentence, concluding that the trial court improperly found as an aggravating factor the “nature and circumstances” of the crime in that “the circumstances articulated by the trial court were essentially elements of the crime.” The Supreme Court affirmed, holding that the trial court did not abuse its discretion in imposing Defendant’s sentence, as the nature and circumstances of the crime were appropriate reasons justifying a sentence greater than the advisory term. View "Gomillia v. State" on Justia Law

Defendant was convicted for class A felony conspiracy to commit robbery resulting in serious bodily injury. Defendant appealed, arguing (1) there was insufficient evidence to support his conviction because the State failed to establish actual serious bodily injury to his alleged victim; and (2) the trial court erred by permitting the State to substantively amend the charging information on the second day of trial. The Supreme Court affirmed, holding (1) the State’s amendment was one of form and not of substance, and the trial court did not err in permitting the change; and (2) the State permitted sufficient evidence at trial to support Defendant’s conviction. View "Erkins v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and of being a habitual offender. The trial court sentenced Defendant to life in prison. Defendant appealed, arguing that the trial court erred in admitting certain evidence and in giving the jury an erroneous limiting instruction. The Supreme Court affirmed, holding (1) the trial court did not err by admitting certain photographs into evidence; (2) the trial court did not err in allowing the introduction of testimony from a state witness; (3) the trial court did not err in admitting evidence of other crimes; and (4) although the trial court erred in giving a limiting instruction directed to the testimony of a witness, the error was not fundamental.View "Halliburton v. State" on Justia Law

After a bench trial, Defendant was convicted of Public Intoxication as a class B misdemeanor. The court of appeals reversed the conviction, concluding that the evidence was insufficient to establish that Defendant had endangered himself or others, one of the statutory elements for Public Intoxication. The Supreme Court granted transfer to consider whether proof of the endangerment element can be established by reasonable inferences drawn from the evidence. The Supreme Court affirmed the trial court, holding that a reasonable fact-finder could find Defendant had been intoxicated in a public place while endangering the life of himself or others beyond a reasonable doubt based on the evidence and the reasonable inferences drawn therefrom. View "Thang v. State" on Justia Law

Defendant pleaded guilty to B-felony burglary and lesser offenses as part of a combined plea agreement. The agreement conferred discretion to determine the placement of Defendant’s executed sentence but had no provision for further restrictive placement for additional suspended time as a condition of probation. The trial court sentenced Defendant to a total of fifteen years for the burglary with five suspended and two of the suspended years served on probation. The court further ordered that the first year of Defendant’s probationary period be spent through work release. The Supreme Court reversed, holding (1) Defendant’s plea agreement conferred discretion on the court to determine the placement of his executed sentence but did not specifically confer discretion over probation; and (2) therefore, Defendant’s one-year term in work release as a condition of probation following the maximum executed term allowing under the agreement exceeded the court’s authority. View "Berry v. State" on Justia Law

Appellant was charged with Resisting Law Enforcement by fleeing after being ordered to stop by a law enforcement officer. After a bench trial, the trial court found Appellant guilty of the charge. On appeal, Appellant argued that the evidence was insufficient to support the conviction. The Supreme Court affirmed, holding (1) the statute defining the offense of Resisting Law Enforcement by fleeing after being ordered to stop must be understood to require that a law enforcement officer’s order to stop be based on reasonable suspicion or probable cause; and (2) under the circumstances of this case, there was not sufficient evidence to prove the element that the officer’s order to stop rested on probable cause or reasonable suspicion. View "Gaddie v. State" on Justia Law

Appellant was found to have violated the terms of his probation by committing Resisting Law Enforcement as a Class A misdemeanor by fleeing. The trial court ordered Appellant to serve three-and-one-half years of his previously suspended sentence. On appeal, Appellant argued that the evidence was insufficient to support the revocation of his probation. The court of appeals affirmed. The Supreme Court granted transfer and affirmed based on the reasoning used in its decision in Gaddie v. State, holding that substantial evidence of probative value supported the trial court’s conclusion that Appellant committed Resisting Law Enforcement. View "Murdock v. State" on Justia Law

After a bench trial, Defendant was convicted of resisting law enforcement and sentenced to ninety days in jail. Defendant appealed, arguing that the evidence was insufficient to sustain his conviction. In this case, Defendant refused repeated orders to lie down on the ground and aggressively advanced, with his fists clenched, to within a few feet of the police officer issuing the orders before being tased. The Supreme Court affirmed, holding that Defendant's act of aggression toward the officer was sufficient to show that Defendant forcibly resisted, obstructed, or interfered with the law enforcement officer pursuant to Ind. Code 35-44.1-3-1(a)(1). View "Walker v. State" on Justia Law

Upon responding to a call about an unsupervised toddler wandering near an apartment-complex retention pond, Defendant informed the police that he was the child’s father. Defendant consented to police entry into his apartment, and the child’s mother, the leaseholder, consented to a full search. The police officers subsequently discovered contraband in the apartment and charged Defendant with unlawful possession of a firearm by a serious violent felon, neglect of a dependent, dealing marijuana, possessing marijuana, and possession of paraphernalia. Defendant pleaded guilty to the neglect and marijuana-possession counts, and the case proceeded to a trial on the remaining counts. During trial, Defendant filed a motion to suppress evidence found during law enforcement’s pat-down search and subsequent search. The trial court denied the motion. Defendant was acquitted of dealing marijuana but found guilty on the remaining charges. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to suppress, as Defendant consented to police entering the apartment, Defendant’s movements justified a pat-down, and the mother gave her consent to search the rest of the apartment. View "McIlquham v. State" on Justia Law