Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
by
The Supreme Court reversed the judgment of the trial court denying Appellant's petition to expunge a minor felony conviction that had been converted to a misdemeanor, holding that the amended statute, which took effect while Appellant's appeal was pending, should apply retroactively to Appellant. At the time Appellant filed his petition the relevant statute required him to wait five years before seeking expungement but wasn't clear on when the waiting period began. Believing the five year period hadn't elapsed, the trial court denied the petition. While Appellant's appeal was pending, the legislature amended the statute to clarify when the five-year waiting period would begin. Both parties acknowledged that, under the amended statute, Appellant would be entitled to expungement. The Supreme Court held that, under the circumstances, the amended statute should apply retroactively to Appellant. View "Gulzar v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court overruling Defendant's motion to suppress evidence obtained during the search of his vehicle, holding that law enforcement officers do not violate either the state or federal constitution by searching a person's vehicle when the person drives that vehicle up to his house while officers are executing a search warrant for the house that does not address vehicles. In his motion to suppress, Defendant argued that the law enforcement in his case exceeded the scope of the search warrant by searching his vehicle, which was not mentioned in the warrant. The trial court denied the motion. The Supreme Court affirmed, holding (1) the general premises warrant permitting law enforcement's search of Defendant's home also supported law enforcement's search of Defendant's vehicle, and therefore, the search did not violate the Fourth Amendment; and (2) the search of Defendant's vehicle did not violate Ind. Const. art. I, 11 because it was reasonable based on the totality of the circumstances. View "Hardin v. State" on Justia Law

by
The Supreme Court reversed the order of the trial court holding Defendant in contempt when Defendant refused to unlock her iPhone for a detective, holding that forcing Defendant to unlock her iPhone would violate her Fifth Amendment right against self-incrimination. The State charged Defendant of several offenses. When Defendant was placed under arrest, law enforcement took her iPhone. Believing it contained incriminating evidence, a detective got a warrant ordering Defendant to unlock her iPhone. When Defendant refused, the trial court held her in contempt. The Supreme Court reversed, holding (1) allowing the State to force Defendant to unlock her iPhone for law enforcement would provide law enforcement with information it did not already know, which the State could use in its prosecution against her; and (2) this result is prohibited by the Fifth Amendment's protection from compelled self-incrimination. View "Seo v. State" on Justia Law

by
The Supreme Court reversed the decision of the trial court denying Defendant's request to file a belated notice of appeal of his twelve-year sentence, holding that the general waiver of Defendant's "right to appeal" was insufficiently explicit to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence. Defendant pleaded guilty to Level 4 felony dealing in methamphetamine and was sentenced to the maximum term of twelve years incarceration. Defendant did not timely file a notice of appeal. Defendant later sought permission to file a belated notice of appeal, arguing that he was only recently made aware of his right to appeal his sentence. The trial court denied Defendant's request. The Supreme Court reversed, holding that the general waiver of Defendant's "right to appeal," particularly when contained in the same sentence as an unenforceable waiver of post-conviction relief, was insufficient to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence. View "Johnson v. State" on Justia Law

by
The Supreme Court revised Defendant's sentence for three counts of level 3 felony rape but otherwise affirmed the court of appeals' decision affirming Defendant's convictions and sentence, holding that exceeding the sentence the prosecutor recommended in this case, absent more significant aggravating factors, was inappropriate. Defendant's convictions arose from his having sexual intercourse with K.S. when she was between twenty-one and twenty-three years old. At issue was whether K.S., who was moderately intellectually handicapped, could legally consent to sex with Defendant. After a mistrial, a second jury convicted Defendant of three counts of rape. The prosecutor recommended that the court impose the advisory sentence of nine years for each of the three counts. The trial court instead sentenced Defendant to enhanced consecutive sentences of twelve years on each count. The court of appeals affirmed. The Supreme Court reversed Defendant's sentence to twenty-seven years, holding that the longer imposed sentence was inappropriate under the circumstances of this case. View "Jackson v. State" on Justia Law

by
The Supreme Court reversed Defendant's guilty but mentally ill (GBMI) conviction to find him not guilty of reason of insanity (NGRI), holding that the State presented insufficient demeanor evidence with which to rebut the unanimous expert opinion and evidence of Payne's history of mental illness. In 2005, Defendant confessed to burning down two bridges and attempting to burn another. Defendant spent most of his life under psychiatric care for chronic paranoid schizophrenia and delusional disorder. The trial court found Defendant incompetent to stand trial until 2016. At his jury trial, Defendant asserted the insanity defense. Three mental health experts concluded that Defendant was unable to distinguish right from wrong. Nevertheless, the jury rejected the insanity defense and found Defendant GMBI on all counts. The court of appeals affirmed. The Supreme Court reversed the GBMI conviction to find Defendant NGRI, holding that the well-documented and consistent history of Defendant's mental illness, along with the unanimous expert opinion, leads to the conclusion that Defendant was insane when the crimes were committed. View "Payne v. State" on Justia Law

by
The Supreme Court reversed the order of the trial court denying Defendant's motion to suppress evidence seized from his home and his father's barn, holding that the search warrants obtained in this case were invalid because the accompanying affidavits did not provide a substantial basis to support the magistrate's probable cause finding. Law enforcement obtained a warrant to plant a GPS tracking device on Defendant's vehicle. When the device stopped providing location readings, the officers discovered that the tracker was no longer attached to Defendant's car. Thereafter, an officer obtained warrants to search Defendant's home and his father's barn for evidence of "theft" of the GPS device. A magistrate issued both search warrants. During the search, officers found drugs, drug paraphernalia, and a handgun. Defendant moved to suppress the seized evidence, arguing that the initial search warrants were issued without probable cause that evidence of theft of the GPS device would be found in his home or his father's barn. The trial court denied the motion. The Supreme Court reversed, holding that the search warrants were invalid because the affidavits did not establish probable cause that the GPS device was stolen and that the good-faith exception to the exclusionary rule did not apply. View "Heuring v. State" on Justia Law

by
The Supreme Court affirmed the decision of the trial court terminating Mother's and Father's parental rights to seven children, holding that there was sufficient evidence to support the court's termination decision. After the trial court found the seven children to be children in need of services, Parents were ordered to complete services, and Father was ordered to complete sex-offender treatment. Father, however, never completed sex-offender treatment because Father refused to admit wrongdoing. The trial court subsequently terminated Parents' parental rights. On appeal, Mother and Father argued that the trial court violated Father's Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding that there was no constitutional violation because the court never ordered Father to admit to a crime and that the evidence supported the trial court's factual findings, which in turn supported its legal conclusions. View "M.H. v. Indiana Department of Child Services" on Justia Law

by
In this case concerning the State's civil complaint for forfeiture of Defendant's Land Rover the Supreme Court vacated the judgment of the trial court deciding that forfeiture of the vehicle would be grossly disproportional to the gravity of Defendant's dealing offense and established an analytical framework for courts to determine whether a punitive in rem forfeiture is an excessive fine. Specifically, the Court held (1) a use-based in rem fine is excessive if (a) the property was not an instrumentality of the underlying crimes, or (b) the property was an instrumentality but the harshness of the punishment would be grossly disproportional to the gravity of the underlying offenses and the owner's culpability for the property's misuse; (2) Defendant's Land Rover was an instrumentality of the underlying offense of drug dealing; and (3) the case requires a remand for the trial court to answer the question of gross disproportionality based on the framework set forth in this opinion. View "State v. Timbs" on Justia Law

by
The Supreme Court affirmed the post-conviction court's denial of Appellant's petition for post-conviction relief alleging ineffective assistance of counsel, holding that that Appellant's arguments were unpersuasive and largely unsupported by the record. Appellant was convicted of two counts of murder and sentenced to death. Appellant petitioned for post-conviction relief, arguing ineffective assistance of counsel. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) trial counsel was not ineffective; (2) Appellant's guilty plea with open sentencing was knowing, intelligent, and voluntary; (3) trial counsel operated under no conflict of interest, and Appellant's conflict of interest claim falls under the Strickland analysis for prejudice, not the presumption of prejudice standard under Cuyler v. Sullivan., 446 U.S. 335 (1980). View "Gibson v. State" on Justia Law