Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of class C felony burglary. The trial court sentenced Defendant to five years in the Indiana Department of Correction, enhanced by eight years for the finding that Defendant was a habitual offender. On appeal, Defendant challenged the sufficiency of the evidence supporting his conviction, arguing that it was unreasonable to infer that he committed the burglary “simply because a glove containing his DNA was found at the scene of the crime.” The Supreme Court affirmed, holding that there was substantial evidence of probative value from which the jury could reasonably infer that Defendant was guilty of burglary beyond a reasonable doubt. View "Meehan v. State" on Justia Law

Appellant pled guilty to murder, murder in the perpetration of a robbery, and robbery. Appellant sentenced to life imprisonment without parole. The Supreme Court subsequently issued an order directing the trial court to revise the sentencing order to comport with precedent and to clarify whether the trial court relied on non-capital aggravators when imposing sentence. The trial court issued a revised sentencing order of life without parole. Appellant appealed, arguing that the order was deficient because it improperly relied on non-statutory aggravators as a basis for imposing a sentence of life imprisonment without parole. The Supreme Court affirmed, holding that the order as revised comported with prior case law and was not an abuse of the trial court’s discretion. View "Rice v. State" on Justia Law

In 2005, Appellant was convicted of a sex crime against an adult female. In 2009, Appellant was released to statutorily mandated parole. The conditions of Appellant’s parole prohibited Appellant from having contact with children, even his own, and included a requirement that Appellant participate in, and successfully complete, a state treatment program for sex offenders. Appellant filed suit, seeking a declaratory judgment as to the constitutionality of those parole conditions. The trial court granted summary judgment to Appellant with respect to the conditions involving Appellant’s family but otherwise denied Appellant summary judgment on his other claims. Before the case reached the Supreme Court, the Parole Board conceded that it no longer sought to impose the parole conditions in a manner that would restrict Appellant’s relationships with his children and wife. The Supreme Court (1) concluded that some of Appellant’s parole conditions were impermissible, including the conditions that were aimed at restricting Appellant from being near or associating with children, as there was no evidence that Appellant was a threat to children; (2) found no fault with the remainder of the conditions; and (3) found no constitutional flaw in the state treatment program. View "Bleeke v. Lemmon" on Justia Law

After a jury trial in 1995, Defendant was found guilty of rape, criminal deviate conduct, and armed robbery. Defendant’s aggregate sentence was imposed in such a way that one of the individual sentences was ordered partially concurrent to the other sentences and partially consecutive. Defendant spent the next decade pursuing relief through an appeal, a petition for post-conviction relief, a petition for a writ of habeas corpus, and a motion for sentence modification, all to no avail. Defendant subsequently filed a motion to correct an erroneous sentence, claiming that the trial court lacked the statutory authority to impose a partially consecutive sentence. The trial court denied Defendant’s motion. The Supreme Court reversed and remanded to the trial court for resentencing, holding that the trial court was not statutorily authorized to impose a partially consecutive sentence like the one Defendant received. View "Wilson v. State" on Justia Law

After Defendant, a high school principal, was told by a student at his school that she had been raped by a fellow student, Defendant did not notify law enforcement or the Department of Child Services for four hours. Defendant was subsequently convicted for failing to immediately report an instance of suspected child abuse occurring within his institution to the police or the Department. Defendant appealed, claiming that the evidence was insufficient to sustain his conviction and that the criminal statute was unconstitutionally vague. The court of appeals reversed, concluding that the State failed to present sufficient evidence that Defendant had reason to believe the student had been a victim of child abuse as required by the reporting statute. The Supreme Court vacated the court of appeals’ judgment and affirmed the conviction and sentence, holding that none of the possible reasons for Defendant’s failure to report the instance of child abuse were acceptable excuses under the Indiana Code. View "Smith v. State" on Justia Law

A law enforcement officer stopped the vehicle Defendant was driving after observing the vehicle driving under the speed limit and coming to a full stop before turning onto a county road, where Defendant drove left of center. Defendant was subsequently charged with operating a vehicle while intoxicated and with an alcohol concentration equivalent of 0.08 or more. The trial court granted Defendant’s motion to suppress on the ground that the officer lacked reasonable suspicion to initiate the traffic stop, taking judicial notice of the poor condition of the county’s roads, which required “evasive action” on the part of drivers. The Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress, holding that, under these circumstances, the trial court did not clearly err in concluding that Defendant’s driving left of center did not provide reasonable suspicion to stop him. View "State v. Keck" on Justia Law

Defendant was charged with four misdemeanors after a law enforcement officer stopped her vehicle for “unsafe lane movement,” conducted field sobriety tests on Defendant, which she failed, and discovered marijuana concealed in Defendant’s clothing. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to justify the stop. The trial court denied Defendant’s motion, concluding that, while a video from the officer’s vehicle did not show Defendant’s vehicle leaving the roadway, it did show Defendant’s vehicle veering onto the white fog line, and to the extent the officer’s testimony conflicted with the video, the testimony was more reliable than the video. The Supreme Court affirmed, holding that, under the totality of the circumstances, the officer’s conduct was reasonable, and the stop was constitutional. View "Robinson v. State" on Justia Law

After a jury trial, Defendant was convicted of four counts of felony attempted child exploitation for taking “upskirt” photographs of women and girls at a mall by means of a concealed shoe camera. The court of appeals reversed, concluding that Defendant did not violate the child exploitation statute, which requires that in order for a defendant to commit child exploitation, the child must “be exhibiting her uncovered genitals with the intent to satisfy someone’s sexual desires.” The Supreme Court granted transfer and affirmed the trial court, holding that the evidence was sufficient to support Defendant’s convictions for attempted child exploitation because, in light of the circumstantial evidence, the jury could reasonably infer that Defendant intended to capture not just images of undergarments but also images of uncovered genitals. View "Delagrange v. State" on Justia Law

Appellant was found guilty of two counts of aggravated battery and sentenced to a term of years in the Department of Correction. The State sought restitution, and the trial court scheduled a restitution hearing. Before the hearing on restitution, Appellant filed a notice of appeal. The State moved to dismiss the appeal on the grounds that the appeal was premature because there had been no resolution of whether or how much restitution would be ordered. The court of appeals subsequently dismissed the appeal as premature. The Supreme Court granted transfer and remanded the case to the court of appeals for consideration of the points raised in Appellant’s brief, holding that, due to confusion about appellate deadlines and in view of the delay already in this case, Appellant’s appeal should be addressed on the merits even though the issue of restitution remained unresolved. Remanded. View "Alexander v. State" on Justia Law

A driver hit Britney Meux, who later died from her injuries, and fled the scene. The State charged the alleged driver, Jason Cozmanoff, with thirteen crimes, including one count of reckless homicide. A few weeks later, Meux’s Estate sued Cozmanoff for wrongful death. The Estate then served Cozmanoff with discovery requests. If Cozmanoff were to invoke the Fifth Amendment and refuse to comply with the Estate’s requests, the civil jury could infer he was liable for causing Meux’s death. But if he were to provide discovery responses, the State could use his testimony and responses against him in his criminal trial. Cozmanoff moved to stay the civil case pending the resolution of his criminal prosecution, citing his Fifth Amendment privilege. The trial court granted a limited stay of discovery but ordered him to respond to the plaintiff’s complaint. The Supreme Court affirmed, holding that, under the circumstances, the trial court did not abuse its discretion in ordering a stay. View "Hardiman v. Cozmanoff" on Justia Law