Justia Indiana Supreme Court Opinion Summaries

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

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