Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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Dustin Lane, a defendant with a history of violent offenses, was serving a prison sentence for domestic battery against his ex-wife, A.N., when he violated a no-contact order by sending her ten letters. These letters, which ranged in tone from loving and apologetic to critical and accusatory, were seen as part of a cycle of manipulation and abuse. Lane was charged with ten counts of Class A misdemeanor invasion of privacy, one for each letter, and pleaded guilty to all counts. The trial court sentenced him to ten 300-day sentences, each to run consecutively, resulting in an aggregate 3,000-day sentence.On appeal, Lane argued that his sentence was inappropriate given the nature of his offenses and his character. The Court of Appeals agreed, finding the sentence inappropriate considering the nature of his offenses, and remanded the case with instructions to impose fully concurrent sentences for an aggregate 300-day term. However, a dissenting judge disagreed, noting Lane's history of violence and the manipulative nature of the letters.The Indiana Supreme Court granted transfer, vacating the opinion of the Court of Appeals. The court noted that Indiana Appellate Rule 7(B) permits reviewing courts to revise a criminal sentence that is “inappropriate in light of the nature of the offense and the character of the offender.” The court found that Lane's violent criminal history and the risk he posed of perpetuating the cycle of domestic abuse against A.N. warranted the lengthy sentence. The court affirmed the trial court's decision, emphasizing the importance of protecting victims and the community from offenders with a history of violence. View "Lane v. State of Indiana" on Justia Law

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The case involves a civil forfeiture action initiated by the State of Indiana against $11,180 found during a search of Dylan Williams's apartment. Williams did not respond to the State's complaint, but his aunt, Angela Smith, intervened, claiming that she owned the money and that it was not connected to any criminal activity. The State argued that the money was tied to criminal activity, specifically drug offenses, based on its location and the denominations in which it was found. The trial court ruled in favor of the State, leading to an appeal by Smith.The case was initially heard in the Marion Superior Court, where the State seized the money and initiated forfeiture proceedings. After a hearing, the trial court ruled in favor of the State, leading to an appeal by Smith. The Indiana Court of Appeals affirmed the trial court's decision.The case was then reviewed by the Indiana Supreme Court. The court found that the State failed to establish a substantial connection between the seized money and any underlying offense. The court also noted that the State did not identify a specific, applicable offense that would subject the money to forfeiture. Furthermore, the court found that Smith presented uncontradicted evidence that the money belonged to her. The court therefore reversed the trial court's forfeiture order and ruled that the money must be returned to Smith. The court also clarified the procedural framework for when the State seeks forfeiture of money and who constitutes an "owner." View "Smith v. State of Indiana" on Justia Law

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The case revolves around Sabrina Dunn, who was charged with murder after shooting her ex-husband, Bill Dunn, in her home. The couple had a history of domestic disputes, with Bill exhibiting erratic and abusive behavior, leading Sabrina to obtain multiple protective orders against him. Despite these orders, Bill continued to harass Sabrina, often breaking into her home. On the day of the incident, Bill entered Sabrina's home uninvited, carrying knives. Fearing for her life, Sabrina shot and killed him.The trial court instructed the jury that the State had to prove beyond a reasonable doubt that Sabrina did not act in self-defense “and/or” in defense of her dwelling. Sabrina was found guilty of murder and sentenced to a maximum term of sixty-five years. The Court of Appeals affirmed the conviction but revised the sentence to fifty-five years with five years suspended.The Indiana Supreme Court, however, found that the use of “and/or” in the jury instructions was ambiguous and potentially misleading. The court noted that the jury needed to understand that the State had to prove that Sabrina did not act in either self-defense or in defense of her dwelling. The ambiguous instructions, the court concluded, could have led the jury to believe that the State only needed to disprove one of these defenses, not both. Given the strength of Sabrina's defense-of-dwelling claim, the court found a serious risk that she was wrongly convicted. As a result, the court vacated Sabrina's murder conviction and remanded the case to the trial court for further proceedings. View "Dunn v. State" on Justia Law

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This case before the Indiana Supreme Court concerns a juvenile, A.W., who was adjudicated for possession of a machine gun and dangerous possession of a firearm. The court was asked to determine if these adjudications violated the principle of double jeopardy under Indiana law. A.W. asserted that he did not know the firearm he possessed had been modified to function as a machine gun.The court found that A.W.'s exclusive possession of the modified gun, along with his abrupt flight from police, supported the conclusion that he knowingly or intentionally possessed a machine gun. This satisfied the first part of the court's inquiry.On the issue of double jeopardy, the court noted that while the Indiana Constitution could apply in juvenile proceedings, it avoided deciding that issue. Instead, it focused on whether possession of a dangerous firearm is a lesser-included offense of possession of a machine gun under the test set out in the case Wadle v. State. The court found that it was, meaning A.W.'s adjudications for both offenses violated his rights under the principle of double jeopardy. Therefore, the court affirmed the finding that A.W. knowingly possessed a machine gun but reversed the adjudication that he committed dangerous possession of a firearm. View "A. W. v. State of Indiana" on Justia Law

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The Indiana Supreme Court vacated the theft convictions of Jennifer Teising, a former township trustee. Teising had been convicted on 21 counts of theft after she moved out of the township she represented and continued to collect her salary while working remotely. The court held that the state did not present sufficient evidence that Teising had the required criminal intent for theft, specifically that she believed she was not supposed to continue collecting her salary. Therefore, the court ruled that without criminal intent, the only available remedies were civil, such as a quo warranto action to remove Teising from office or a conversion claim to recover allegedly misappropriated money. View "Teising v. State of Indiana" on Justia Law

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In 2022, Richard Allen was charged with the murder of two teenage girls in Indiana. Due to his inability to afford a lawyer, the trial court appointed public defenders Andrew Baldwin and Brad Rozzi to represent him. After about a year, the special judge overseeing the case grew concerned about the effectiveness of Baldwin and Rozzi and disqualified them over Allen's objections, replacing them with new public defenders and postponing Allen's trial by nine months to give the new lawyers time to prepare.Allen then hired two appellate attorneys who filed a Verified Petition for Writ of Mandamus with the Indiana Supreme Court, asking for the reinstatement of Baldwin and Rozzi, a trial start within seventy days, and a new special judge. The Indiana Supreme Court granted Allen's request to reinstate his original counsel, but denied his other two requests.The court found that the trial court did not demonstrate that disqualifying Baldwin and Rozzi was a necessary last resort after considering the prejudice to Allen. Furthermore, Allen's request for a trial within seventy days was denied because he did not make this request in the trial court. Finally, the court denied Allen's request to replace the special judge, as he did not provide sufficient evidence to suggest that the special judge was biased or prejudiced.The court also found that Allen's petition presented extraordinary circumstances for which there was not an adequate appellate remedy. Thus, reviewing the trial court’s disqualification decision was appropriate through an original action. Moreover, disqualifying Allen’s counsel delayed his trial by at least nine months, and the trial court has already concluded that Allen’s pretrial confinement presents extraordinary challenges. Hence, the court concluded that Allen's petition presented the sort of extraordinary circumstances for which there is not an adequate appellate remedy. View "State ex rel. Allen v. Carroll Circuit Court" on Justia Law

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In November 2021, Tailar Spells was arrested and charged with Level 6 felony battery by bodily waste and Class A misdemeanor resisting law enforcement. A $250 cash bond was set, which was deposited in full by a third party, and both Spells and the depositor signed a cash-bond agreement, permitting the court to retain all or part of the cash to pay for public defense costs and any fines, costs, fees, and restitution that the court may order Spells to pay if convicted. Spells was convicted on the battery charge but acquitted of resisting law enforcement. The court imposed a sentence, including a $20 fine and $185 in various fees and court costs, and later granted a request to apply $245 from Spells's cash bond to her fine, costs, and fees. Spells appealed, arguing that the trial court had failed to adequately inquire into her ability to pay.The Indiana Supreme Court held that under the cash-bond agreement, the court was allowed to retain the entirety of Spells's public defense costs without an indigency determination. However, the court could retain cash bail to pay most other fines, costs, and fees only after considering Spells's ability to pay. The indigency determination in Spells's case was found to be incomplete, thus warranting partial remand to the trial court. The court ruled that an indigency hearing is necessary before retaining cash bail to pay most other fines, costs, and fees. The court also clarified the standard for indigency determinations, noting that the record of such determination must disclose evidence of the defendant's assets, income, and necessary expenses. View "Spells v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court in this action seeking to confiscate money under Indiana's civil forfeiture statute, holding that the right to a jury trial applies in such an action.The State filed a complaint to forfeit $2,435 in cash that police officers recovered after stopping Alucious Kizer for a traffic violation, alleging that the money had been "furnished or intended to be furnished" in exchange for a crime, that it had been "used to facilitate" a crime, or that it was "traceable as proceeds" of a crime. Kizer requested a jury trial. The State moved to strike the demand, arguing that no such right existed under either the Indiana or United States Constitution. The court of appeals reversed, concluding that Kizer was not entitled to trial by jury. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court, holding (1) Ind. Const. Art. I, 20 protects the right to a jury trial for in rem civil forfeitures; and (2) therefore, Kizer had a constitutional right to trial by jury. View "State v. $2,435 in U.S. Currency" on Justia Law

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The Supreme Court vacated Defendant's sentence of consecutive prison terms totaling forty-nine years in connection with his conviction of two counts of child molesting, holding that Defendant did not waive his right to be physically present at sentencing.Following his conviction, Defendant became sick and could not be transported to the courthouse for sentencing. Defendant's original sentencing hearing was continued to a new date, but before the new sentencing date, Defendant was hospitalized for a leg amputation. On the day of the sentencing hearing, the trial court, court reporter, prosecutor, and defense counsel traveled to the hospital and concluded that Defendant waived his right to be present at the hearing. The trial court proceeded to sentence Defendant. The Supreme Court vacated the sentence and remanded for a new sentencing hearing, holding that, under these circumstances, this Court could not condone a sentencing hearing at a hospital. View "Williams v. State" on Justia Law

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The Supreme Court dismissed Defendant's appeal of the sentence imposed in connection with his plea of guilty to four theft-related charges, holding that Defendant's written plea agreement with the State, which both he and his attorney signed, unambiguously waived his right to appeal his sentence.In exchange for a more lenient sentence, Defendant agreed to plead guilty to four theft-related charges and waive his right to appeal his conviction and sentence. The trial court accepted Defendant's plea and sentenced him to four years for burglary and thirty months for theft, ordering the sentences to run concurrently. Defendant appealed, but the court of appeals dismissed the appeals with prejudice. The Supreme Court affirmed, holding that this Court could not nullify Defendant's appeal waiver through direct appeal based on the claim that the waiver was not knowing and voluntary, but Defendant could still seek relief through post-conviction proceedings. View "Davis v. State" on Justia Law