Justia Indiana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder and sentenced to life imprisonment without the possibility of parole (LWOP). The Supreme Court affirmed in all respects, holding (1) the trial court did not err in admitting six crime-scene photographs into evidence, and expert witness’s reliance on the photographs was admissible; (2) the trial court did not abuse its discretion in denying Defendant’s motion for a mistrial as a sanction for undisclosed testimony; (3) the trial court did not err in its instructions to the jury; and (4) the LWOP sentence was supported by sufficient evidence, the jury was not invited to recommend LWOP based on non-stautory aggravators, and the sentence was proportionate and appropriate. View "Knapp v. State" on Justia Law

After police officers received information about a drug dealer, the officers approached a vehicle in which Appellant was a passenger, ordered her outside the car, and handcuffed her. While Appellant was being interviewed, another officer began an inventory search of the vehicle and found cocaine. Appellant was charged with two drug-related felonies. Appellant moved to suppress the evidence found during the search of her vehicle and the statements she made to the interviewing officer. The trial court denied the motion except as to the statements Appellant made before she received a Miranda warning. The Supreme Court reversed the trial court's denial of Appellant's motion to suppress, holding (1) the officers did not have probable cause to arrest Appellant or to search her vehicle; and (2) a reasonable person in Appellant's shoes would not have understood the Miranda warning to convey a message that she retained a choice about continuing to talk, and therefore, Appellant's post-Miranda statements were inadmissible. Remanded.View "Kelly v. State" on Justia Law

Defendant, a truck driver, was arrested after a deliberate action conducted by the state police uncovered nearly ninety pounds of cocaine in Defendant's cargo. Defendant requested a speedy trial, but the trial court was unable to bring him to trial within the time limit because of court congestion. Defendant filed a motion for discharge, which the trial court denied. Defendant also unsuccessfully moved to suppress the evidence obtained as a result of the traffic stop. Ultimately, Defendant was convicted of two counts of dealing in cocaine. Defendant appealed. The Supreme Court affirmed the admission of cocaine evidence at Defendant's trial and the denial of his motion for discharge, holding (1) neither the police officers' detentions of Defendant nor the collective police action constituted an unreasonable search or seizure; and (2) the trial court's decision to continue Defendant's trial beyond his seventy-day speedy trial window was not clearly erroneous.View "Austin v. State" on Justia Law

Defendant, a non-native English speaker, pleaded guilty to one count of delivery of cocaine within one thousand feet of a school. Ten years later, Defendant filed a petition for post-conviction relief alleging that his plea was not entered knowingly, intelligently and voluntarily because the court-appointed interpreted failed to accurately translate Defendant’s Boykin rights. The post-conviction court denied relief. The court of appeals affirmed, determining that the advisement was defective but, nonetheless, Defendant knew at the time of the plea hearing that he was waiving his Boykin rights. The Supreme Court reversed, holding that Defendant was not properly advised of the constitutional rights he was waiving by pleading guilty and did not understand his constitutional rights when he purportedly waived them. View "Ponce v. State" on Justia Law

After a jury trial, Defendant was convicted of resisting law enforcement, battery of a law enforcement officer resulting in injury, and disorderly conduct. The court of appeals affirmed. Defendant appealed, arguing that the trial court erred in giving only the pattern jury instruction regarding the defense of another and not his tendered jury instructions. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in refusing to give Defendant's tendered instructions, as the Indiana Pattern Jury Instruction is a correct statement of the law and continues to serve as the primary guide for trial judges on the issues of self-defense or defense of another. Remanded to the trial court to correct the abstract of judgment.View "Washington v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and class B felony possession of a firearm by a serious violent felon (SVF). Defendant appealed, claiming (1) the trial court should have given his tendered jury instruction on self-defense, and (2) the trial court erred by not completely bifurcating the trial on his SVF charge from the trial on his murder charge. The Supreme Court affirmed Defendant's convictions, holding that the trial court did not err (1) in utilizing the existing Indiana Pattern Jury Instruction on self-defense and in refusing to give Defendant's tendered jury instruction; and (2) in partially bifurcating the trial. View "Russell v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony sexual misconduct with a minor. Defendant appealed, arguing that several statements made by the State during closing argument constituted prosecutorial misconduct. Because Defendant did not raise any objection to the prosecutor’s remarks during trial, Defendant contended that the remarks cumulatively resulted in fundamental error. The court of appeals agreed with Defendant and reversed his convictions. The Supreme Court granted transfer, thereby vacating the court of appeals, and affirmed the judgment of the trial court, holding (1) the prosecutor engaged in one instance of misconduct; but (2) because of the absence of any timely objection by Defendant, reversal was not warranted. View "Ryan v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown and fifteen-year-old Defendant, robbed two victims in their home. The victims were killed during the robbery. Defendant was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Defendant to an aggregate sentence of 150 years, the same sentence imposed on Brown. The Supreme Court revised the 150-year sentence received by Brown and similarly exercised its constitutional authority to revise Defendant’s sentence, holding that Defendant’s sentence “foreswears altogether the rehabilitative ideal” and concluding that Defendant should total aggregate sentence of eight-five years imprisonment. View "Fuller v. State" on Justia Law

In 2010, three teenagers, including sixteen-year-old Martez Brown, robbed two victims in their home. The victims were killed during the robbery. Brown was found guilty of two counts of murder and one count of robbery. The trial court ultimately sentenced Brown to an aggregate sentence of 150 years, the same sentence imposed on Brown’s cohorts. The Supreme Court revised the 150-year sentence received by Brown, holding that Brown’s sentence “foreswears altogether the rehabilitative ideal,” and concluded that Brown should be sentenced to an enhanced sentence to a total aggregate sentence of eighty years imprisonment. View "Brown v. State" on Justia Law

On September 19, 2011, the trial court sentenced Defendant. On December 5, 2012, Defendant filed a motion to modify her sentence. On March 5, 2013, the trial court granted Defendant’s motion for modification. The State appealed, arguing that the trial court lacked authority to modify Defendant’s sentence because more than 365 days had passed since Defendant was sentenced and the prosecutor did not affirmatively approve of the modification. The Supreme Court affirmed, holding that the trial court did not err in granting Defendant’s motion for sentence modification, where, in the context of the interactions and communications between the trial court and the prosecutor in this case, the prosecutor’s conduct adequately conveyed the “approval of the prosecuting attorney” required in Ind. Code 35-38-1-17(b). View "State v. Harper" on Justia Law