Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to dismiss the State's habitual-offender allegation and remanded with instructions to vacate Defendant's habitual-offender enhancement, holding Defendant's constitutional right to a speedy trial was violated by a six-plus-year delay.Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual-offender enhancement. More than six years passed before the State retried the habitual-offender allegation. Defendant filed a motion to dismiss, but the trial court denied the motion, eventually finding Defendant to be a habitual offender. The Supreme Court reversed, holding (1) Criminal Rule 4(C) does not apply to a habitual-offender retrial; but (2) Defendant's right to a speedy trial was violated, and therefore, Defendant was entitled to relief. View "Watson v. State" on Justia Law

The Supreme Court revised the maximum 138-year sentence imposed on Defendant for crimes he committed as a juvenile, holding that the sentence was inappropriate.In 1991, seventeen-year-old Defendant and two others committed a murder and other crimes. Defendant received a total sentence of 138 years, the maximum possible term-of-years sentence. The Supreme Court affirmed on appeal. In 2016, Defendant filed a petition for post-conviction relief, challenging the propriety of imposing the maximum term-of-years sentence on him for crimes committed as a juvenile. The post-conviction court granted the petition and imposed an aggregate sixty-eight-year sentence. The Supreme Court affirmed the post-conviction court's order granting relief and revised the sentence to eighty-eight years, holding that the 138-year sentence was inappropriate. View "State v. Stidham" on Justia Law

The Supreme Court vacated K.C.G.'s delinquency adjudication and the modification of his probation based on that adjudication, holding that the juvenile court lacked subject matter jurisdiction.The delinquency at issue alleged that sixteen-year-old K.C.G. committed the offense of dangerous possession of a firearm in violation of Ind. Code 35-47-10-5. The juvenile court adjudicated K.C.G. a delinquent and modified his probation. On appeal, Defendant argued that the plain terms of the dangerous-possession statute showed it could not be a delinquent act. The Supreme Court vacated the delinquency adjudication, holding that because the statute defines the offense solely in terms of a "child" with an unauthorized firearm, the dangerous-possession statute does not apply to adults, and therefore, the State's petition did not allege a jurisdictional prerequisite - that K.C.G.'s conduct was "an act that would be an offense if committed by an adult." View "K.C.G. v. State" on Justia Law

The Supreme Court reduced Defendant's sentence imposed in connection with his conviction for two counts of murder, Class B felony armed robbery, and a Class D felony conspiracy to commit criminal gang activity, holding that Defendant's appellate counsel was ineffective on direct appeal by failing to bring an Appellate Rule 7(B) challenge to the appropriateness of Defendant's sentence.Defendant was sixteen years old when he committed the crimes underlying his convictions. On post-conviction review, Defendant argued that his sentence of 181 years constituted a de facto juvenile life sentence that violated the Eighth Amendment. The post-conviction court denied relief. The Supreme Court revised Defendant's sentence downward to an aggregate 100 years, holding (1) Defendant's original sentence was not unconstitutional because the protections outlined in Miller v. Alabama, 567 U.S. 460 (2012), for juvenile life-without-parole sentences are inapplicable to a term of years sentence; but (2) appellate counsel's failure to challenge the sentence's appropriateness amounted to deficient performance, and Defendant was prejudiced by the failure. In the interest of judicial economy, the Supreme Court conducted a review of the sentence under Appellate Rule 7(B) and revised the sentence downward. View "Wilson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of the murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct and that, under the circumstances, Defendant did not demonstrate that the misconduct probably harmed him.After Defendant was convicted, he filed a motion to set aside the verdict based on juror misconduct, alleging that one juror, L.W., falsely answered the juror questionnaire. The juror wrote "N/A," meaning not applicable, in response to questions about the jurors past criminal history and whether she had been a victim of a crime, when those answers should have been a yes. The trial court denied Defendant's motion to set aside the verdict. The Supreme Court affirmed, holding (1) juror L.W. committed gross misconduct; but (2) despite the gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of dealing in a look-a-like substance, a Level 5 felony under Ind. Code 35-348-4-4.6, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant offered to sell a substance to a strange at a casino, and the incident was captured by video surveillance. A gaming enforcement agent took Defendant to an interview room, patted him down, and found packaged drugs. Defendant moved to suppress the evidence stemming from the pat-down. The trial court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that the search and seizure proceeded within the bounds of the Fourth Amendment, and therefore, the trial court did not err in denying Defendant's motion to suppress. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding a statute stopping the City of Bloomington's proposed annexation of several areas of land and prohibiting the City from attempting to annex the areas for five years unconstitutional, holding that the statute is unconstitutional special legislation in violation of Ind. Const. art. IV, 23.While Bloomington was taking steps toward annexation, the General Assembly passed Ind. Code 36-4-3-11.8 cutting off the City's proposed annexation and prohibiting the City from trying to annex the same areas for the next five years. The City sought declaratory and injunctive relief. The trial court granted summary judgment for the City, declaring the statute unconstitutional under Article 4, Sections 19 and 23 of the Indiana Constitution. The Supreme Court affirmed, holding (1) the City can bring this declaratory judgment action against the Governor; and (2) section 11.8 is unconstitutional special legislation. View "Holcomb v. City of Bloomington" on Justia Law

The Supreme Court reversed the determination of the trial court finding Mother in contempt of court and ordering that Father have sole legal and physical custody of the parties' infant child, holding that the court abused its discretion by conflating Mother's contempt of court with the best interest of the child.Father filed a petition for rule to show cause alleging that Mother had violated a previous order by relocating the parties' child from Indiana. The trial court granted full relief to Father, finding Mother in contempt for relocating the child out of Indiana and for denying Father parenting time. The court then ordered that Father have sole legal and physical custody of the child. The Supreme Court reversed, holding that where Mother's alleged contempt appeared to be the catalyst for the trial court's order granting Father sole legal and physical custody, the trial court's order could not stand. View "Yanes-Mirabal v. Badasay" on Justia Law

The Supreme Court reversed the decision of the trial court denying Defendant's petition for expungement, holding that because the trial court may have denied the petition on the erroneous belief that Ind. Code 35-38-9-4(b)(3) rendered Defendant ineligible for expungement, the case must be remanded.Defendant pled guilty to Class B felony conspiracy to commit burglary. After Defendant completed all the terms of his probation without any violations and waiting the required three years he petitioned for expungement. The trial court denied the petition without explaining its reasoning. The Supreme Court reversed, holding (1) a trial court may consider facts incident to the conviction when evaluating an expungement petition; and (2) a trial court should first determine whether the conviction is eligible for expungement and then whether it merits expungement; and (3) because the trial court did not articulate its reasons for denying Defendant's petition, the case is remanded with instructions for the court to reconsider its decision consistent with this opinion. View "Allen v. State" on Justia Law

In this case involving an agreement to arbitrate, the Supreme Court reiterated the elements of equitable estoppel required for an outside party not contemplated by the agreement to enforce an arbitration clause against a signatory and reversed the trial court's determination that a third party could compel arbitration, holding that none of the traditional elements of equitable estoppel were satisfied.Jane Doe's legal guardian (Guardian) arranged for Jane to live at Carmel Senior Living (CSL) and initialed an arbitration agreement. Guardian later filed a complaint against CSL; its management company, Spectrum; and one of its employees, claiming that the employee had sexually abused Jane and that CSL and Spectrum (together, CSL) were vicariously liable. Guardian later amended the complaint to add Certiphi Screening, the company CSL had hired to run background checks on new employees. The defendants demanded arbitration. The trial court granted the motions to compel arbitration, concluding that the agreement covered CSL and that equitable estoppel mandated arbitration of Guardian's claims against Certiphi. The Supreme Court reversed in part, holding that Certiphi did not meet the requirements of equitable estoppel. View "Doe v. Carmel Operator, LLC" on Justia Law