Justia Criminal Law Opinion Summaries

In 2005, Defendant was sentenced to seventeen years in prison. In 2010, Defendant struck a prison employee in the face. Defendant was found guilty of battery with injury and sentenced to an enhanced term of three years. The trial court ordered a consecutive sentence as statutorily required but awarded Defendant 471 days credit for time he served incarcerated prior to trial on the battery charge plus 471 days of Class I credit time for a total credit of 942 days against the battery sentence. The State subsequently filed a motion to correct erroneous sentence, which the trial court denied. The Supreme Court remanded the case to the trial court with instructions to re-evaluate the award of credit time and to re-sentence Defendant, holding that the trial court erred in awarding credit time with respect to the mandatory consecutive sentence. View "State v. Lotaki" on Justia Law

The State charged Defendant with class D felony sexual battery. Defendant, who was born in 1943, filed a motion for a competency determination. Doctors evaluating Defendant diagnosed him with dementia, concluded that he was not competent to stand trial, and predicted that he would not be able to be restored to competency. Based on the doctors’ reports and without a hearing, the trial court found that Defendant was not competent to stand trial and that he could not be restored to competency. The State then requested that the court commit Defendant to the Division of Mental Health and Addiction (DMHA) pursuant to Ind. Code 35-36-3-1(b). The trial court denied the motion. The Supreme Court reversed the trial court’s denial of the State’s motion to commit Defendant to the DMHA, holding that section 35-36-3-1(b) requires trial courts to commit defendants found not competent to stand trial to the DMHA for competency restoration services. Remanded. View "State v. Coats" on Justia Law

After a jury trial, Defendant was convicted of murder, felony murder, robbery, and unlawful possession of a firearm by a serious violent felon. Defendant was sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) Ind. Code 35-50-2-9(1) is constitutional and its constitutionality does not require that the weighing of aggravators and mitigators be done beyond a reasonable doubt; (2) the trial court did not commit prejudicial error in its rulings regarding admission of evidence, use of an exhibit, instruction on felony murder, provision of a definition of asportation, and denial of surrebuttal; and (3) Defendant’s life sentence without the possibility of parole was appropriate. View "Inman v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary as a class C felony and theft as a class D felony. The court of appeals affirmed. The Supreme Court granted transfer to address Defendant's argument that the trial court erred by admitting DNA evidence in violation of his Sixth Amendment right to confrontation. The Supreme Court affirmed the judgment of the trial court, holding that the trial court did not err in admitting certain DNA evidence, as the Constitution does not require a laboratory technician involved in the chain of custody of DNA evidence to testify at trial in order to satisfy the demands of a defendant's Sixth Amendment right of confrontation. View "Speers v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and of being a habitual offender. The trial court sentenced Defendant to life in prison. Defendant appealed, arguing that the trial court erred in admitting certain evidence and in giving the jury an erroneous limiting instruction. The Supreme Court affirmed, holding (1) the trial court did not err by admitting certain photographs into evidence; (2) the trial court did not err in allowing the introduction of testimony from a state witness; (3) the trial court did not err in admitting evidence of other crimes; and (4) although the trial court erred in giving a limiting instruction directed to the testimony of a witness, the error was not fundamental. View "Halliburton v. State" on Justia Law

After a bench trial, Defendant was convicted of resisting law enforcement and sentenced to ninety days in jail. Defendant appealed, arguing that the evidence was insufficient to sustain his conviction. In this case, Defendant refused repeated orders to lie down on the ground and aggressively advanced, with his fists clenched, to within a few feet of the police officer issuing the orders before being tased. The Supreme Court affirmed, holding that Defendant's act of aggression toward the officer was sufficient to show that Defendant forcibly resisted, obstructed, or interfered with the law enforcement officer pursuant to Ind. Code 35-44.1-3-1(a)(1). View "Walker v. State" on Justia Law

After police officers received information about a drug dealer, the officers approached a vehicle in which Appellant was a passenger, ordered her outside the car, and handcuffed her. While Appellant was being interviewed, another officer began an inventory search of the vehicle and found cocaine. Appellant was charged with two drug-related felonies. Appellant moved to suppress the evidence found during the search of her vehicle and the statements she made to the interviewing officer. The trial court denied the motion except as to the statements Appellant made before she received a Miranda warning. The Supreme Court reversed the trial court's denial of Appellant's motion to suppress, holding (1) the officers did not have probable cause to arrest Appellant or to search her vehicle; and (2) a reasonable person in Appellant's shoes would not have understood the Miranda warning to convey a message that she retained a choice about continuing to talk, and therefore, Appellant's post-Miranda statements were inadmissible. Remanded. View "Kelly v. State" on Justia Law

Defendant, a truck driver, was arrested after a deliberate action conducted by the state police uncovered nearly ninety pounds of cocaine in Defendant's cargo. Defendant requested a speedy trial, but the trial court was unable to bring him to trial within the time limit because of court congestion. Defendant filed a motion for discharge, which the trial court denied. Defendant also unsuccessfully moved to suppress the evidence obtained as a result of the traffic stop. Ultimately, Defendant was convicted of two counts of dealing in cocaine. Defendant appealed. The Supreme Court affirmed the admission of cocaine evidence at Defendant's trial and the denial of his motion for discharge, holding (1) neither the police officers' detentions of Defendant nor the collective police action constituted an unreasonable search or seizure; and (2) the trial court's decision to continue Defendant's trial beyond his seventy-day speedy trial window was not clearly erroneous. View "Austin v. State" on Justia Law

After a jury trial, Defendant was convicted of resisting law enforcement, battery of a law enforcement officer resulting in injury, and disorderly conduct. The court of appeals affirmed. Defendant appealed, arguing that the trial court erred in giving only the pattern jury instruction regarding the defense of another and not his tendered jury instructions. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in refusing to give Defendant's tendered instructions, as the Indiana Pattern Jury Instruction is a correct statement of the law and continues to serve as the primary guide for trial judges on the issues of self-defense or defense of another. Remanded to the trial court to correct the abstract of judgment. View "Washington v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and class B felony possession of a firearm by a serious violent felon (SVF). Defendant appealed, claiming (1) the trial court should have given his tendered jury instruction on self-defense, and (2) the trial court erred by not completely bifurcating the trial on his SVF charge from the trial on his murder charge. The Supreme Court affirmed Defendant's convictions, holding that the trial court did not err (1) in utilizing the existing Indiana Pattern Jury Instruction on self-defense and in refusing to give Defendant's tendered jury instruction; and (2) in partially bifurcating the trial. View "Russell v. State" on Justia Law