Justia Indiana Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court revoking Defendant's community corrections placement for possessing obscene matter, holding that the evidence was insufficient to revoke Defendant's probation for possession of obscene matter.When community corrections officers performed a compliance check at Defendant's home they found a cell phone containing pictures of Defendant, as well as pictures of a naked woman and videos with a man and woman engaging in sexual intercourse. The community corrections portion of Defendant's sentence was revoked. On appeal, Defendant argued that because the trial court expressly stated that not all parts of the obscene matter definition were met, the evidence was insufficient to support revocation of his probation. The Supreme Court reversed, holding that reversal was necessary because the trial court made factual findings that negated one part of the statutory definition required to prove the violation. View "Bennett v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony neglect of a dependent resulting in her death, holding that the trial court did not abuse its discretion in admitting evidence at trial that Defendant had, on prior occasions, used a pillow to muffle his infant daughter's crying.On appeal, Defendant argued that the evidence of prior pillow incidents was inadmissible under Ind. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the State may introduce other-bad-acts evidence to show lack of accident only when the State has reliable assurance that an accident defense will be raised or after the defendant places the accident at issue on trial; (2) in the instant case, because the State was reliably assured that Defendant would raise an accident defense, it could properly introduce the Rule 404(b) evidence; and (3) there was no abuse of discretion in admitting that evidence because the evidence's prejudicial effect did not outweigh its probative value. View "Fairbanks v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony resisting, holding that the challenged instruction in this case potentially misled the jury as an incorrect statement of law but that the jury charge, as a whole, cured the instructional defect.Specifically, the Court held (1) Defendant did not invite the alleged instructional error; (2) the challenged instruction misstated the mens rea and threatened to mislead the jury, and therefore, the use of the instruction is disapproved of going forward; but (3) the jury charge provided adequate instructions on the correct statutory elements and standard of proof, and the instructional defect was harmless. The Court then summarily affirmed Defendant’s convictions for felony battery and misdemeanor resisting, holding that Defendant failed to explain how instructional error affected his felony battery and misdemeanor resisting convictions. View "Batchelor v. State" on Justia Law

The Supreme Court held that the Fee Exemption, a provision in Ind. Code 36-1-20-5 that allows the cities of Bloomington and West Lafayette to charge local landlords any amount to register rental properties, is unconstitutional special legislation that must be struck down but that the remainder of section 36-1-20-5 remains in force.While the Fee Exemption singles out the cities of Bloomington and West Lafayette for preferential treatment, all other Indiana localities are restricted to charging only $5 under another provision - the Fee Restriction - in section 36-1-20-5. The City of Hammond challenged the Fee Exemption as unconstitutional under Ind. Const. art. IV, 23. The Supreme Court agreed with the City and held that the Fee Exemption is unconstitutional but that the remainder of the statute, including the Fee Restriction, remained in effect and now operates statewide. View "City of Hammond v. Herman & Kittle Properties, Inc." on Justia Law

The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt.Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt. View "Zanders v. State" on Justia Law

The Supreme Court reversed the judgment of the lower courts denying Appellant’s petition for post-conviction relief on the basis that his attorney provided deficient performance that prejudiced him, holding that counsel rendered ineffective assistance to Appellant by failing to properly advise him about the immigration consequences of a misdemeanor guilty plea.Appellant pleaded guilty to stealing less than twenty dollars of merchandise from Walmart without realizing that his guilty plea made him a deportable felon under federal immigration law. Appellant sought post-conviction relief, alleging ineffective assistance of counsel. The lower courts denied relief. The Supreme Court reversed, holding (1) Appellant’s attorney rendered constitutionally deficient performance as a matter of law by independently marking “N/A” next to the citizenship advisement on the standard advisement of rights from before inquiring into Appellant’s citizenship status; and (2) counsel’s deficient performance prejudiced Appellant. View "Bobadilla v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment in favor of the Town of Yorktown’s Clerk-Treasurer, Beth Neff, holding that the State’s request to remove Neff did not fall within the exceptionally rare category of cases that warranted removal.Relying on Indiana Code 5-8-1-35, the Removal Statute, the State sought Neff’s removal for her alleged refusal or neglect to perform the official duties pertaining to her office. The trial court entered judgment in favor of Neff, concluding that Neff had not completely failed to carry out her duties. The Supreme Court affirmed, holding (1) for a public official to be removed pursuant to subsection (a)(2) of the Removal Statute, the State must show that the official has generally failed to perform his or her official duties; and (2) Neff’s failures and errors did not result in such a general failure, and therefore, the removal statute did not apply. View "State v. Neff" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained after Defendant was stopped for speeding, holding that there was reasonable suspicion for a traffic stop under the circumstances.At issue was whether there was reasonable suspicion for the traffic stop where the police officer’s calibrated radar indicated that an oncoming vehicle was speeding and the officer verified the radar speed exceeded the posted speed limit but failed to document the excessive speed. The trial court denied Defendant’s motion to suppress on the basis that the officer’s stop of Defendant was based upon his observation that a traffic infraction was being committed. The Supreme Court affirmed, holding that the traffic stop passed muster under both the United States and Indiana Constitutions. View "Marshall v. State" on Justia Law

The Supreme Court reversed the trial court’s grant of partial summary judgment on David Shaner’s claim for damages related to loss of consortium after his wife Laura’s death due to complications with the administration of dialysis treatments, holding that the wrongful death and survival statutes enable David’s claim to survive regardless of the existence of an heir.In his complaint, David sought two categories of damages contemplated by Indiana’s wrongful death statute: damages related to medical hospital, funeral, and burial expenses; and additional damages including loss of consortium, loss earnings and wages, and loss of additional employment benefits. David died during litigation, leaving no immediately ascertainable heirs. In moving for partial summary judgment on the loss of consortium claim, Defendants argued that any damages in excess of medical, hospital, funeral, and burial expenses would only serve to punish Defendants because the damages would pass to the State. The trial court granted the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that David’s claim for survivor damages could have survived regardless of the existence of an heir, and therefore, summary judgment on this claim was inappropriate. View "Horejs v. Milford" on Justia Law

The Supreme Court terminated the disciplinary proceedings relating to the circumstances giving rise to this judicial misconduct case, holding that continued litigation would be an inefficient use of judicial resources because the court over which Respondent presided no longer existed and because Respondent consented to a prohibition on future judicial service.The Supreme Court, however, wrote in order to clarify municipal courts’ power to administer infraction cases and infraction deferral agreements and to caution judicial officers on the impropriety of assuming the prosecutor’s duties. The Court then held (1) municipal courts’ status as “special courts” does not absolve them of the duties of a separate but co-equal branch of government; and (2) municipal court judges must endeavor to maintain, preserve, and protect the independence of Indiana’s judiciary even when administering the lowest-level civil and criminal offenses. View "In re Honorable Geoff L. Robison" on Justia Law