Justia Indiana Supreme Court Opinion Summaries

In this case, the State filed charges against Defendant, and after a brief period of incarceration, Defendant was released. Shortly after his release, Defendant was again incarcerated but on a probation-revocation case. While he was incarcerated on the probation-revocation case, Defendant filed a Ind. R. Crim. P. 4(B) motion requesting a speedy trial on the pending charges. The trial court denied the motion. The Supreme Court affirmed, holding (1) Rule 4(B) is available to a defendant only when the defendant is held on the pending charges for which he requests a speedy trial; and (2) accordingly, Rule 4(B) was not available to Defendant on the pending charges for which he sought a speedy trial because he was not incarcerated on those charges. View "Cundiff v. State" on Justia Law

Brice Webb was charged with murder in the shooting death of his girlfriend. Webb requested a jury instruction on the lesser offense of reckless homicide. The trial court denied the request and Webb was convicted as charged. The Supreme Court reversed Webb's conviction and remanded the cause for a new trial, holding that the trial court's refusal to instruct the jury on the lesser-included offense of reckless homicide was reversible error, as the evidence in this case produced a serious evidentiary dispute concerning Webb's state of mind, and whether Webb acted knowingly or recklessly, that would justify giving the requested instruction. View "Webb v. State" on Justia Law

The trial court revoked the probation of Troy Smith for failure to pay weekly child support as a condition of his probation. On appeal, Smith argued that the State failed to carry its burden of proof that his failure to pay was reckless, knowing, or intentional. The Supreme Court affirmed the judgment of the trial court, holding (1) it is the defendant probationer's burden to show facts related to an inability to pay and indicating sufficient bona fide efforts to pay so as to persuade the trial court that further imprisonment should not be ordered; and (2) here, Smith failed to carry his burden, and therefore, the trial court did not abuse its discretion in revoking Smith's probation. View "Smith v. State" on Justia Law

A jury found Rodney Nicholson guilty of stalking and harassment, and Nicholson admitted to being a habitual offender. A majority of the court of appeals held that a span of twenty-two months between contacts would not fit the definition of repeated or continuing harassment and therefore would not support a conviction for stalking. The Supreme Court granted transfer and affirmed the trial court, holding that the lag in time between the harassing calls in 2006 and subsequent single call in 2008 did not foreclose the conviction for stalking, as there was no statutorily determine timeframe required for a stalking conviction and there was sufficient evidence for the trier of fact to determine Nicholson engaged in stalking. View "Nicholson v. State" on Justia Law

Defendant was charged with felony robbery, felony theft, and felony receiving stolen property. Before trial, the trial court permitted a late filing of a habitual-offender charge. The jury found Defendant was guilty of theft and receiving stolen property and determined that White was a habitual offender. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals but summarily affirming the court of appeals' decision that the two convictions violated double jeopardy principles (resulting in vacation of Defendant's conviction for receiving stolen property). The Court then held (1) under the circumstances of this case, Defendant did not preserve the issue of whether the trial court properly allowed the habitual-offender filing; and (2) the authenticated and certified evidence was sufficient to uphold the jury's determination that Defendant was a habitual offender. View "White v. State" on Justia Law

Defendant Harold Klinker managed and owned Trucks Unlimited (Trucks), a used-car dealership. Plaintiff First Merchants Bank (FMB) financed Trucks' vehicle inventory. After it was discovered that thirty-one vehicles for which FMB had loaned purchase money were not in Trucks' possession, FMB filed an eight-count complaint against Klinker, Trucks, and others (only Klinker appealed), alleging fraud, among other claims. FMB moved for summary judgment on seven counts, but by then only twenty-two vehicles were missing. The trial court nevertheless granted summary judgment to FMB on all seven counts and awarded treble damages and attorney's fees on the fraud claims under the Indiana Crime Victims' Compensation Act. The Supreme Court reversed the judgment on the fraud claims and treble-damages claims because there were genuine issues of material fact as to whether Defendant acted with the requisite criminal intent. View "Klinker v. First Merchants Bank, N.A." on Justia Law

Rebecca Kays was convicted of misdemeanor battery and sentenced to 180 days in jail, suspended to twelve months probation. The trial court ordered as a term of probation that Kays pay restitution in the amount of $1,496. Kays appealed, arguing that the trial court improperly ordered restitution as a term of probation because her only source of income was social security disability benefits. The court of appeals reversed, holding that restitution may not be based on social security income, and therefore, the trial court could not take into account Kays' social security income in determining her ability to pay. The Supreme Court granted transfer, thereby vacating the court of appeals, and reversed the trial court. The Court held that social security benefits may be considered by a trial court in determining a defendant's ability to pay restitution, but the trial court erred in failing to determine Kays' ability to pay restitution and to determine her manner of payment. View "Kays v. State" on Justia Law

Jimmie Jones was charged with murder. At trial, Jones tendered instructions on reckless homicide and involuntary manslaughter as lesser included offenses to the murder charge. The trial court refused Jones's instructions, finding that those lesser included offenses were not supported by the evidence. A jury later found Jones guilty of murder. On appeal, Jones disputed that his tendered instructions were not supported by the evidence. The court of appeals affirmed. The Supreme Court granted transfer and affirmed the judgment of the trial court after adopting the opinion of the court of appeals, which concluded that the trial court had not abused its discretion by finding no serious evidentiary dispute. View "Jones v. State" on Justia Law

A jury found Jesse Harris guilty of murder and two counts of attempted murder. The trial court sentenced Harris to a total of 165 years incarceration. The court of appeals affirmed. Harris appealed, contending that the State engaged in forum shopping. The Supreme Court granted transfer, thus vacating the court of appeals, to clarify that a defendant claiming a violation of a local felony case assignment rule need not establish prejudice to prevail on appeal. The Court affirmed Harris's conviction, holding (1) the trial court correctly interpreted the rule, and (2) no violation of the rule occurred in this case. View "Harris v. State" on Justia Law

A jury found Keith Hoglund guilty of two counts of child molesting. The court of appeals affirmed. Hoglund appealed, contending the testimony of expert witnesses constituted impermissible vouching evidence. The Supreme Court granted transfer, thereby vacating the court of appeals. The Court then affirmed the judgment of the trial court, holding (1) testimony amounting to the equivalent that a witness believes the child in a case involving child sex abuse allegations is telling the truth is inconsistent with the rules of evidence; (2) the trial court erred in allowing expert testimony that commented on the child witness' truthfulness into evidence over Hoglund's objection; but (3) because Hoglund's conviction was supported by substantial independent evidence of his guilt, and because the improper admission of the evidence was cumulative of other evidence properly before the jury, the error in admitting the testimony was harmless. View "Hoglund v. State" on Justia Law