Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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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

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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

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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

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The Supreme Court affirmed Defendant's conviction for murder and felony murder and entering a revised order sentencing Defendant to life imprisonment without parole (LWOP) for his murder conviction, holding that the revised order did not rely on non-statutory aggravating circumstances to impose LWOP. On appeal, Defendant argued that the LWOP sentence must be vacated because the trial court impermissibly relied on non-statutory aggravating circumstances. The Supreme Court disagreed, holding that Defendant offered no evidence to suggest that the revised order relied on non-statutory aggravating circumstances to impose LWOP. View "Schuler v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of stalking, holding that a charge of stalking may be supported by conduct that is continuous in nature, even if it is a single episode. The statutory definition of stalking requires repeated or continuing harassment. Defendant's actions that led to his conviction involved following a college student's vehicle for more than two hours as she attempted to evade him. Even though Defendant's actions took place over the course of less than three hours the court of appeals affirmed Defendant's conviction and sentence, concluding that Defendant's actions amounted to repeated or continuing harassment or impermissible contact. The Supreme Court affirmed after clarifying that a charge of stalking may be supported by conduct that is purely continuous in nature, holding that Defendant's conduct met the statutory definition of "continuing" harassment, thereby supporting his conviction for stalking. View "Falls v. State" on Justia Law

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The Supreme Court reversed the judgment of the trial court convicting Defendant of two counts of operating a vehicle while intoxicated, holding that the trial court abused its discretion in refusing to conduct a hearing regarding the possible bias of a juror who, after being selected to serve on the jury but before being sworn, submitted a note informing the trial court that one of her family members had been killed by a drunk driver. Defense counsel requested an opportunity to explore the juror's potential bias, but the trial court did not allow further questioning. The Supreme Court reversed Defendant's convictions and remanded the proceedings for a new trial, holding that the information conveyed by the juror to the trial court before the jury was sworn should have resulted in a hearing to determine whether Defendant could properly have challenged the juror's service for cause. View "Easler v. State" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing in part Defendant's convictions, holding that that the court of appeals' effort to correct a double jeopardy violation misconstrued Paquette v. State, 101 N.E.3d 234 (Ind. 2018) (Paquette I). The trial court convicted Defendant of three counts of resisting law enforcement by fleeing in a vehicle causing death, a Level 3 felony, operating a vehicle with methamphetamine in his blood causing serious bodily injury, a Level 4 felony, and two Level 6 felonies. In Defendant's first appeal, the Supreme Court held, among other things, that the resisting law enforcement statute does not contemplate multiple convictions when multiple victims were killed as a result of a single incident of resisting. After the case was remanded, the court of appeals reversed in part. The Supreme Court held that the court of appeals misconstrued Paquette I by vacating the Level 3 felony conviction instead of one of the three Level 4 felony convictions. The Court then remanded for the trial court to impose judgment for one count of Level 3 felony resisting law enforcement causing death, two counts of Level 4 felony operating causing death, and one count of Level 6 felony operating causing serious bodily injury and to sentence accordingly. View "Paquette v. State" on Justia Law

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The Supreme Court vacated the decision of the court of appeals revising Defendant's sentence for three counts of Class A felony child molesting and revised the sentences to the original terms set by the trial court, holding that the sentence imposed by the court of appeals was wholly inadequate under the circumstances. The trial court sentenced Defendant to consecutive terms of thirty years on each count of his conviction for child molesting for an executed sentence of ninety years, with twenty years suspended. The court of appeals revised Defendant's sentence to concurrent thirty-year terms, with no time suspended, on all three counts. The Supreme Court granted vacated the court of appeals' decision and revised Defendant's sentences to the original consecutive thirty-year temps, with thirty years suspended, for an executed sentence of sixty years, holding that a thirty-year aggregate sentence was inadequate under the circumstances. View "Faith v. State" on Justia Law

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In this post-conviction proceeding, the Supreme Court held that a post-conviction petition that addresses only the proceedings on remand from a federal court's grant of a new trial is not a "second" or "successive" petition under Ind. Post-Conviction Rule 1(12) and that such a petition may proceed without the prior authorization of the Supreme Court or the court of appeals. Defendant filed a petition for post-conviction relief alleging ineffective assistance of counsel in his criminal proceedings. The post-conviction court and court of appeals denied the petition. Defendant then filed a petition for writ of habeas corpus, which the federal district court denied. The federal court of appeals vacated the district court's judgment and remanded with instructions to issue a writ of habeas corpus unless the State granted Defendant a new appeal. Defendant subsequently filed a second direct appeal, which the court of appeals denied. Defendant filed another petition for post-conviction relief, alleging that his appellate attorney failed properly to argue the issues in his new direct appeal. The trial court dismissed the petition as an unauthorized successive petition under Rule 1(12). The Supreme Court remanded for further proceedings, holding that because the petition addressed only the grounds arising from the second appeal, it may proceed without prior appellate authorization. View "Shaw v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and other crimes and sentencing him to life without parole, holding that each of Defendant's contentions on appeal were without merit. Specifically, the Court held (1) sufficient evidence supported Defendant's conviction for auto theft, and the Court needn't address Defendant's felony-murder challenge because the trial court merged those verdicts with his murder convictions; (2) any error in the trial court's admonishments to the jurors each time they were separated wasn't fundamental; (3) the trial court did not violate Defendant's Confrontation Clause rights by admitting post-crime text messages of Defendant's co-conspirator because the messages weren't testimonial; (4) any error in the decision of the trial court to read a withdrawn accomplice liability instruction was harmless; and (5) the trial court did not manifestly abuse its discretion when it sentenced Defendant to life without parole. View "Cardosi v. State" on Justia Law