Justia Indiana Supreme Court Opinion Summaries

Defendant pleaded guilty to attempted residential entry and resisting law enforcement. Defendant failed to appear at his sentencing hearing. Counsel moved for a continuance of the sentencing hearing, but the trial court denied a continuance. After a hearing held in Defendant’s absence, the court sentenced Defendant. Defendant appealed, arguing that the trial court abused its discretion in denying his motion to continue the sentencing hearing and that the maximum sentence on the attempted residential entry conviction was inappropriate under Appellate Rule 7(B). The court of appeals sua sponte reversed on other grounds. The Supreme Court granted transfer and affirmed, holding (1) the trial court did not abuse its discretion in denying a continuance; and (2) the sentence imposed by the trial court was not inappropriate under Appellate Rule 7(B). View "Robinson v. State" on Justia Law

At issue in this case was what constitutes sufficient evidence to prove a person intentionally or knowingly violated a protective order.K.G., the pastor of a small Indiana church, sought a protective order against Defendant, a parishioner. The court issued a protective order prohibiting Defendant from “harassing, annoying, telephoning, contacting, or directly or indirectly communicating with” K.G. After Defendant emailed three elders at the church, she was convicted of two counts of invasion of privacy for knowingly or intentionally violating the order. The jury found Defendant guilty. Defendant appealed, arguing that the evidence was insufficient to support the conviction. A majority of the Court of Appeals reversed, concluding that Defendant’s intent in sending the email was not to contact K.G. but to ask the church elders to discipline or punish K.G. for alleged wrongful conduct. The Supreme Court granted transfer and affirmed Defendant’s conviction, holding that the jury acted within its discretion in discrediting Defendant’s testimony and finding that Defendant intentionally or knowingly communicated with K.G. through her email. The court also affirmed Defendant’s sentence, holding that the trial court did not abuse its discretion by considering Defendant’s criminal history as an aggravating circumstance and that Defendant’s sentence was appropriate considering her offense and character. View "Phipps v. State" on Justia Law

At issue in this case was what constitutes sufficient evidence to prove a person intentionally or knowingly violated a protective order.K.G., the pastor of a small Indiana church, sought a protective order against Defendant, a parishioner. The court issued a protective order prohibiting Defendant from “harassing, annoying, telephoning, contacting, or directly or indirectly communicating with” K.G. After Defendant emailed three elders at the church, she was convicted of two counts of invasion of privacy for knowingly or intentionally violating the order. The jury found Defendant guilty. Defendant appealed, arguing that the evidence was insufficient to support the conviction. A majority of the Court of Appeals reversed, concluding that Defendant’s intent in sending the email was not to contact K.G. but to ask the church elders to discipline or punish K.G. for alleged wrongful conduct. The Supreme Court granted transfer and affirmed Defendant’s conviction, holding that the jury acted within its discretion in discrediting Defendant’s testimony and finding that Defendant intentionally or knowingly communicated with K.G. through her email. The court also affirmed Defendant’s sentence, holding that the trial court did not abuse its discretion by considering Defendant’s criminal history as an aggravating circumstance and that Defendant’s sentence was appropriate considering her offense and character. View "Phipps v. State" on Justia Law

Defendant, who was charged with voluntary manslaughter without also being charged with murder, was properly found guilty even where the State conceded the existence of sudden heat to support the standalone charge.On appeal, Defendant argued that the State was required to prove sudden heat and that the State’s concession rendered his self-defense defense illusory. The Court of Appeals reversed, ruling that the State failed to present sufficient evidence that Defendant acted with sudden heat. The Supreme Court granted transfer and affirmed the conviction, holding (1) although the jury was instructed that the State conceded the existence of sudden heat, there was evidence that Defendant acted in either sudden heat or self-defense, and therefore, the jury was presented with a classic question of fact; and (2) the State’s concession of sudden heat did not nullify Defendant’s claim of self-defense. View "Brantley v. State" on Justia Law

Defendant, who was charged with voluntary manslaughter without also being charged with murder, was properly found guilty even where the State conceded the existence of sudden heat to support the standalone charge.On appeal, Defendant argued that the State was required to prove sudden heat and that the State’s concession rendered his self-defense defense illusory. The Court of Appeals reversed, ruling that the State failed to present sufficient evidence that Defendant acted with sudden heat. The Supreme Court granted transfer and affirmed the conviction, holding (1) although the jury was instructed that the State conceded the existence of sudden heat, there was evidence that Defendant acted in either sudden heat or self-defense, and therefore, the jury was presented with a classic question of fact; and (2) the State’s concession of sudden heat did not nullify Defendant’s claim of self-defense. View "Brantley v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and conspiracy to commit murder and sentencing him to life imprisonment without parole for the murder conviction. The Supreme Court held (1) the State presented sufficient evidence to support Defendant’s convictions, and the court declined to reweigh the evidence; (2) the trial court did not commit reversible error in admitting certain evidence to which Defendant objected; and (3) Defendant’s life without parole sentence for murder was both constitutionally proportional and appropriate under Appellate Rule 7(B). View "McCallister v. State" on Justia Law

The boundary separating public trust land from privately-owned riparian land along the shores of Lake Michigan is the common-law ordinary high water mark (OHWM). Absent an authorized legislative conveyance, the State retains exclusive title up to that boundary.In this case, the trial court determined that the State holds title to the Lake Michigan shores in trust for the public and concluded that the private property interests at issue here overlap with those of the State. The Supreme Court affirmed in part and reversed in part, holding (1) Indiana, at statehood, acquired exclusive title to the bed of Lake Michigan up to the natural OHWM; (2) Indiana retains exclusive title up to the natural OHWM of Lake Michigan; and (3) at a minimum, walking along the Lake Michigan shore is a protected activity inherent in the exercise of traditional public trust rights. View "Gunderson v. State" on Justia Law

The Department of Correction’s change to Indian’s lethal injection protocol, which added Brevital to the lethal injection cocktail, does not carry the effect of law, and therefore, the new three-drug protocol is not a rule and thus not subject to the Administrative Rules and Procedures Act (ARPA).In 2014, the Department announced hat it would alter the three-drug combination used for executions, replacing Sodium Thiopental with Brevital. Plaintiff, a death row inmate, filed a complaint alleging that the Department’s change to the lethal injection protocol violated his rights under the ARPA. The trial court dismissed the complaint for failure to state a claim. The Court of Appeals reversed, ruling that the Department’s execution protocol constituted a rule, and because the Department failed to follow ARPA’s requirements when adding Brevital to the three-drug combination, the changed protocol was void. The Supreme Court vacated the Court of Appeals, holding that the Department’s lethal injection protocol did not constitute a “rule” for APRA purposes. View "Ward v. Carter" on Justia Law

The Department of Correction’s change to Indian’s lethal injection protocol, which added Brevital to the lethal injection cocktail, does not carry the effect of law, and therefore, the new three-drug protocol is not a rule and thus not subject to the Administrative Rules and Procedures Act (ARPA).In 2014, the Department announced hat it would alter the three-drug combination used for executions, replacing Sodium Thiopental with Brevital. Plaintiff, a death row inmate, filed a complaint alleging that the Department’s change to the lethal injection protocol violated his rights under the ARPA. The trial court dismissed the complaint for failure to state a claim. The Court of Appeals reversed, ruling that the Department’s execution protocol constituted a rule, and because the Department failed to follow ARPA’s requirements when adding Brevital to the three-drug combination, the changed protocol was void. The Supreme Court vacated the Court of Appeals, holding that the Department’s lethal injection protocol did not constitute a “rule” for APRA purposes. View "Ward v. Carter" on Justia Law

A trial court judge is not required to recuse himself or herself from a case solely because counsel for one of the parties served as a professional reference and wrote a recommendation letter in support of the judge’s application for another judicial role.In this contested adoption case, Father alleged that because the trial judge listed adoptive parents’ counsel as a reference in his application for appointment to the Indiana Supreme Court, an appearance of impropriety was created, necessitating the trial judge’s recusal. The judge denied the motion for recusal and then dismissed Father’s motion to contest the adoption and entered a decree of adoption. The Supreme Court affirmed and remanded the case, holding that, under the facts and circumstances of this case, the trial judge was not required to recuse himself on remand. View "L.G. v. S.L." on Justia Law