Justia Indiana Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Coleman v. Indiana
Defendant Tyrus Coleman shot Anthony Dye and Jermaine Jackson during a confrontation on Defendantâs property. The State charged Defendant with murder and attempted murder. At trial, Defendant testified and admitted to the shootings, but maintained that he shot in self-defense. Defendant was acquitted on the murder charge, but a mistrial was entered on the attempted murder charge. Before he could be retried, Defendant filed a motion to dismiss the attempted murder charge arguing that the State was âcollaterally estoppedâ from bringing the same case against him, and that if allowed to proceed, the second trial would constitute double jeopardy. The trial court denied that motion, and a retrial was held. The second jury found Defendant guilty as charged. The trial court sentenced Defendant to forty-five yearsâ imprisonment. A divided appellate court reversed Defendantâs conviction on collateral estoppel grounds. The Supreme Court held that collateral estoppel and double jeopardy did not preclude the State from retrying Defendant after a mistrial had been declared. The Court reversed the appellate courtâs decision, and affirmed the trial courtâs judgment.
Barnes v. Indiana
A jury convicted Appellant Richard Barnes of misdemeanor charges involving battery, disorderly conduct, and resisting arrest. Appellant contested his conviction by raising technical errors at trial, specifically that the trial court did not advise the jury of his right to reasonably resist what he considered the officersâ unlawful entry to his apartment on the day he was arrested. The Supreme Court reviewed the trial record, and found that there is no right to âreasonably resistâ an entry by police officers. Furthermore, the Court held that the evidence was sufficient to support Defendantâs conviction, and affirmed the lower courtâs decision.
Wilkins v. Indiana
Facing felony drugs and firearms charges, Appellant Damion Wilkins sought to suppress evidence obtained when police executed a search warrant of a home. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
Lacey v. Indiana
Facing felony drugs and firearms charges, Appellant Cornelius Lacey, Sr. sought to suppress evidence obtained when police executed a search warrant of a home he was in. The trial court denied his motion, and Appellant appealed. The appellate court reversed the lower court. On interlocutory appeal to the Supreme Court, Appellant argued that police were not justified in their âno knockâ execution of the warrant. Appellant maintained that the record did not reflect sufficient âexigent circumstancesâ to justify the police bypassing the âknock and announceâ rule. The Supreme Court found that Appellant was not entitled to suppression of the evidence relating to the no-knock search. The Court affirmed the trial courtâs denial of his motion to suppress.
Konopasek v. Indiana
In June, 2008, Appellant Joshua Konopasek attended a house party in Rochester. At some point, he got into an altercation with another party-goer. The evening ended with Appellant shoving the other party-goer to the ground and stomping on his head. Appellant would later be charged with battery causing serious injury. Appellant claimed self-defense. On direct examination, Appellantâs attorney elicited testimony from him regarding his probationary status. On cross-examination, the State inquired further about appellantâs probation. Defense counsel objected that the stateâs inquiry was irrelevant. The trial court overruled the objection. Petitioner was found guilty as charged, and sentenced to eight yearsâ imprisonment, with six suspended and credit for time served. On appeal, Petitioner argued that there was insufficient evidence to convict him of battery, and that the trial court abused its discretion by admitting the evidence elicited by the State on his probation. The appellate court affirmed the trial court. The Supreme Court agreed too, holding that the Stateâs elicited testimony on the length of Petitionerâs suspended sentence was relevant and admissible. Furthermore, the Court found the evidence sufficient to support his conviction. The Court affirmed the lower courtsâ decisions.
Serrano v. Indiana
Appellant Martin Serrano lost his truck in a forfeiture action based on the presence of cocaine residue found in the carpet of the vehicle, and on a box of quarters. Appellant challenged the sufficiency of the evidence, contending that the State failed to prove that the presence of cocaine in his truck was anything more than "incidental or fortuitous." The Court of Appeals agreed with Appellantâs argument. The Supreme Court found that though Appellant admitted he was a cocaine user, âthere are numerous ways that cocaine residue may have made its way into the truck that [did] not involve the use of the vehicle in furthering the possession of cocaine.â The Supreme Court affirmed the appellate courtâs decision.
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Criminal Law, Indiana Supreme Court