Justia Indiana Supreme Court Opinion Summaries

After a 911 call was made by a motorist complaining that the driver of a blue Volkswagen, who had just pulled into a gas station, was driving erratically, a police officer arrived at the gas station and observed the blue Volkswagen. The officer then made an investigatory stop of the driver of the vehicle, Amanda Renzulli. Renzulli was later charged with operating a vehicle while intoxicated. The trial court granted Renzulli's motion to suppress the evidence on the grounds that there was no reasonable suspicion for the stop. The Supreme Court reversed, holding that, based on the totality of the circumstances, the police officer in this instance had reasonable suspicion based on articulable facts to briefly detain Renzulli for investigatory purposes. View "State v. Renzulli" on Justia Law

The Indiana Constitution authorizes the General Assembly to disenfranchise "any person convicted of an infamous crime." Plaintiff was convicted of misdemeanor battery. During his incarceration, Plaintiff was informed that his voter registration was canceled in accordance with several provisions of state law under which persons convicted of crimes and sentenced to imprisonment are disenfranchised for the duration of incarceration. After his release, Plaintiff filed a lawsuit seeking declaratory and injunctive relief against state and county election officials. The Supreme Court accepted certification to answer whether Plaintiff's constitutional rights were violated when his voter registration was canceled because, as Plaintiff alleged, misdemeanor battery was not an "infamous crime." The Court held (1) the crime in this case was not an "infamous crime," but (2) the General Assembly has separate constitutional authority to cancel the registration of any person incarcerated following conviction for the duration of the incarceration, and (3) therefore, Plaintiff's Constitutional rights were not violated when he was disenfranchised while incarcerated. View "Snyder v. King" on Justia Law

Appellant was charged with tattooing a minor for taking his former Stepdaughter to get a tattoo. While the charge was pending, a detective arranged for Stepdaughter to make recorded phone calls to Appellant to obtain evidence concerning a sexual relationship Appellant allegedly forced upon Stepdaughter. The State subsequently charged Appellant with several sex-related crimes. Appellant moved to suppress the incriminating statements from the conversations, claiming they were obtained in violation of his right to counsel. The trial court denied the motion and convicted Appellant as charged. The court of appeals affirmed. At issue before the Supreme Court was whether an "inextricably intertwined" exception to the offense-specific nature of the right to counsel existed under the state Constitution. The Court affirmed, holding (1) under the Indiana Constitution, the right to counsel is violated only where the different offense is inextricably intertwined with the charge on which counsel is already representing the defendant; and (2) because there was no evidence that it would have been objectively foreseeable for the detective, at the time he conducted the phone calls, to believe the pending tattooing offense was inextricably intertwined with the alleged sexual misconduct, the recorded conversations did not violate Appellant's right to counsel. View "Jewell v. State" on Justia Law

Appellant pled guilty to driving while intoxicated after proceeding pro se in plea negotiations with the State. Appellant filed a petition for postconviction relief, alleging that his waiver of counsel was invalid. The trial court denied the petition. The Supreme Court granted transfer and announced that future defendants expressing a desire to proceed without counsel must be informed that an attorney is more experienced in plea negotiations and better able to identify and evaluate potential defenses and problems in the prosecution's case (Hopper warning). The Court subsequently granted the State's petition for rehearing and affirmed the post-conviction court, holding (1) the Sixth Amendment does not require the same warnings and analysis for a valid waiver of counsel during plea negotiations as it requires for the entry of a guilty plea; (2) the post-conviction court properly found that Hopper's waiver of counsel during his guilty plea hearing was voluntary and intelligent; and (3) the absence of the Hopper warning is not a per se violation of a defendant's right to counsel, but rather, courts should consider the absence of the instruction as an additional factor in a totality of the circumstances approach. View "Hopper v. State" on Justia Law

A trial court found Lisa Gray guilty of possessing marijuana as a class A misdemeanor. The court of appeals set aside the conviction on the grounds of insufficient evidence. At issue on appeal was whether the trial court properly found Gray had constructive possession of the marijuana when it was found on the floor of her apartment and Gray's son testified that the marijuana belonged to him. The Supreme Court granted transfer, vacated the court of appeals, and affirmed the trial court, holding that there was substantial evidence of probative value from which the court could have found beyond a reasonable doubt that Gray committed the crime. View "Gray v. State" on Justia Law

After a jury trial, Appellant Otha Hamilton was convicted of one count of molesting a child for an incident in which Appellant's nine-year-old step-granddaughter performed oral sex on him. Hamilton was sentenced to the maximum sentence of fifty years in prison. Hamilton appealed, arguing, inter alia, that the sentence was inappropriate given the nature of his offense and his character. The court of appeals affirmed the conviction and sentence. The Supreme Court affirmed Hamilton's conviction but revised his sentence, holding that, given the nature of Hamilton's sexual misconduct, the sentence imposed by the trial court was inappropriate. Remanded with instructions to enter an amended sentence of thirty-five years in prison. View "Hamilton v. State" on Justia Law

Jeffery Cain was convicted of murder and robbery and sentenced to life without the possibility of parole. Cain appealed his conviction and sentence, claiming that a co-defendant's testimony was improperly admitted at the guilt phase of his trial and that the prosecutor made inappropriate arguments during the sentencing phase. The Supreme Court affirmed, holding (1) under the circumstances, the trial court was well within its discretion to deny Cain's motion to exclude the co-defendant's testimony; and (2) although the prosecutor inaccurately portrayed education programs for offenders in her closing argument during the sentencing phase of Cain's trial, the prosecutor's statements did not qualify as fundamental error. View "Cain v. State" on Justia Law

Defendant Nathan Brock was charged with one count of violating Ind. Code 9-30-10-17, which makes it a felony for a habitual traffic violator to operate a motor vehicle after his or her driving privileges have been forfeited for life, and one count of felony resisting law enforcement. The trial court granted the State's motion for a mistrial due to improper prejudicial comments made by defense counsel during closing argument. Before the second trial was set to begin, Brock filed a motion to dismiss on double-jeopardy grounds. The trial court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, although Defendant did not consent to the mistrial, his second trial did not violate the Double Jeopardy Clause of the Fifth Amendment because the trial court did not abuse its discretion in concluding that a mistrial was justified by manifest necessity. View "Brock v. State" on Justia Law

Mother's parental rights to her Child were terminated by the juvenile court after Mother's incarceration. The court of appeals affirmed. Mother appealed, alleging several due process violations on the part of the Department of Child Services (DCS). The Supreme Court affirmed, holding (1) if any error existed in DCS's failure to locate Mother, which resulted in Mother's absence from the termination hearing, it did not substantially increase the risk of error in her termination proceeding; (2) a misrepresentation by DCS on an affidavit, in this limited instance, did not violate Mother's due process rights; (3) a delay from DCS in serving Mother with a Child in Need of Services petition upon locating Mother was inappropriate, but a reversal was not warranted in this case because the dilatory action did not result in fundamental error or deprive Mother of due process; (4) whether an incarcerated parent is permitted to attend a termination hearing is within the sound discretion of the trial court judge, and therefore, Mother's due process rights were not violated by her absence from the trial; and (5) the evidence in this case supported the trial court's findings that termination of the parent-child relationship was in Child's best interests. View "Z.G. v. Dep't of Child Servs." on Justia Law

While driving on a county road, Pamela Price encountered ice across the roadway and lost control of her vehicle, sustaining personal injury and property damage. Earlier that morning, after a different driver lost control of his vehicle at the same location, a deputy of the county sheriff department arrived at the scene and advised the county highway department of the icy condition. Price filed a complaint against, among others, the sheriff department and highway department, alleging negligence. The sheriff department and highway department filed a motion to dismiss for failure to state a claim upon which relief can be granted, which the trial court denied. The sheriff department sought interlocutory review. The court of appeals granted review and affirmed. The Supreme Court vacated the court of appeals and reversed the judgment of the trial court, holding that because the sheriff department neither owned, maintained, nor controlled the county road, it did not owe a common law duty to warn the public of known hazardous conditions upon the roadway. View "Putnam County Sheriff v. Price" on Justia Law