Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's sentence of life imprisonment without the possibility of parole (LWOP) in connection with his conviction for the murder and burglary of his ex-girlfriend, holding that Defendant's LWOP sentence was not inappropriate.On appeal, Defendant argued that the jury failed to meet all statutory prerequisites for an LWOP sentence by failing to determine that the aggravating circumstances outweighed the mitigating circumstances and that his sentence was inappropriate in light of the mental illness he was suffering when he committed the crimes. The Supreme Court affirmed, holding (1) the jury's LWOP recommendation reflected its determination that the aggravating circumstances outweighed the mitigating circumstances; and (2) the LWOP sentence was not inappropriate. View "Oberhansley v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal of his sentence, holding that Appellant's written plea agreement with the State unambiguously waived his right to appeal his sentence.Appellant pled guilty to four theft-related offenses in exchange for a more lenient sentence. Both Appellant and his attorney signed a three-page plea agreement with the State in which Appellant waived his right to appeal his sentence. Appellant sought to appeal his sentence despite his plea agreement. The Supreme Court dismissed the appeal, holding (1) Appellant waived his right to appeal his sentence; and (2) if Appellant's guilty plea was not knowing and voluntary because the trial judge's misstatements misled him as to which rights he was waiving, Appellant's remedy was to vacate his conviction through post-conviction relief proceedings. View "Davis v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's denial of Appellant's post-conviction petition for permission to file a belated notice of appeal, holding that the appeal should be allowed to proceed.In 1999, Appellant pleaded guilty to burglary, robbery, rape, and criminal confinement, all felonies. In 2021, Appellant filed a petition for post-conviction relief seeking to file a belated notice of appeal under Rule 2 and claiming that when he signed his guilty plea there was no advisement that he had the right to appeal his sentence and that he did not learn of his ability to appeal until that that year. The trial court denied the petition without holding an evidentiary hearing, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant was not at fault in failing to file a timely notice of appeal and was diligent in pursuing his belated notice of appeal. View "Leshore v. State" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the judgment of the criminal court entering an order in limine excluding from evidence the juvenile court's order in a child in need of services (CHINS) proceedings, holding that the trial court did not abuse its discretion by excluding the CHINS order.The Department of Child Services (DCS) filed a petition alleging that E.H., who was less than fourteen years old, was a CHINS. The juvenile court denied the petition after a fact-finding hearing. After further investigation, the State charged Defendant with Level 5 felony battery resulting in bodily injury to E.H. When Defendant sought to introduce at trial the CHINS order as evidence that someone else likely injured E.H. the State filed a motion to exclude that evidence in limine. The trial court granted the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by excluding the CHINS order under the circumstances of this case. View "Means v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of involuntary manslaughter, holding that the trial court violated Ind. Trial Rule 47(D) by denying defense counsel the opportunity to voir dire prospective jurors directly and that the error was not harmless.As the State acknowledged at oral argument, the parties agreed at the time of this opinion, that the trial court violated Trial Rule 47(D) during voir dire when it prohibited defense counsel from questioning prospective jurors directly. The Supreme Court reversed Defendant's conviction and remanded the case for a new trial, holding (1) the trial court went beyond setting reasonable limits on voir dire; and (2) the error was not harmless. View "Doroszko v. Indiana" on Justia Law

The Supreme Court affirmed Defendant's conviction of the murder of her ten-year-old stepdaughter, S.C., and her sentence of life without parole, holding that the State sufficiently carried its evidentiary burden to disprove the existence of "sudden heat" because of a lack of adequate provocation, accompanied by a sustained cooling-off period.At issue was whether the State failed to satisfy its evidentiary burden in negating the mitigating factor of "sudden heat," the necessary condition to reduce Defendant's conviction to voluntary manslaughter. The Supreme Court affirmed Defendant's conviction and life-without-parole sentence, holding that the State satisfied its evidentiary burden in negating the mitigating factor and voluntary manslaughter requirement of sudden heat. View "Carmack v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for murder and two counts of attempted murder, holding that the jury permissibly resolved the issues of fact raised on appeal against Defendant.On appeal, Defendant argued that the evidence did not support his convictions because the jury could not have found beyond a reasonable doubt that he was the shooter at issue. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to identify Defendant as the shooter; (2) the doubts Defendant raised about the evidence presented factual disputes that the jury was entitled to resolve; and (3) the jury could reasonably have resolved an inconsistency in the evidence in the State's favor. View "Young v. State" on Justia Law

The Supreme Court reversed Defendant's convictions for several drug-related offenses, holding that the trial court abused its discretion by admitting evidence obtained during a search of Defendant's home.Officer Cody Scott was investigating a robbery when he detained Defendant for an outstanding warrant for his arrest. The officer asked Defendant if he would escort him inside the house, and Defendant agreed to the request. After Officer Scott observed possible narcotics in the residence he obtained a search warrant, the execution of which revealed various drug paraphernalia. The court of appeals affirmed Defendant's convictions, holding that the trial court did not abuse its discretion by denying Defendant's motion to suppress. The Supreme Court reversed, holding that Defendant's protections under Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), were violated in this case, and therefore, the trial court abused its discretion by admitting evidence obtained during the search. View "McCoy v. State" on Justia Law

The Supreme Court overruled State ex rel. Keaton v. Circuit Court of Rush County, 475 N.E.2d 1146 (Ind. 1985), which held that criminal trial courts do not have inherent authority to require the State to produce complete copies of police reports over the prosecuting attorney's timely work product objection, holding that Trial Rule 26(B)(3) supersedes Keaton.In making its holding in Keaton the Supreme Court cited an undue burden on prosecuting attorneys and the potential for abuse by defense counsel. Noting that the majority of prosecutors across the State regularly produce police reports to defendants while the minority automatically assert the work product privilege over those documents the Supreme Court reconsidered its decision in Keaton. The Court then overruled Keaton, holding (1) the decision in Keaton conflicts with Indiana's liberal discovery rules, including Trial Rule 26(B)(3); and (2) the reasons justifying the Court's decision in Keaton are improper considerations in a work product analysis and unsupported in today's modern age. View "Minges v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of six offenses, including unlawful possession of a firearm by a serious violent felon in violation of Ind. Code 35-50-2-8, holding that none of Defendant's allegations of error required reversal.On appeal, Defendant argued that the trial court erred in giving Preliminary Instruction 18, and that the error was fundamental. The court of appeals agreed and reversed. The Supreme Court granted transfer and affirmed, holding (1) Defendant invited any error that arose from Preliminary Instruction 18, which precluded relief on direct appeal; (2) the traffic stop leading to Defendant's arrest did not violate the Fourth Amendment; and (3) Defendant waived his last allegation of error. View "Miller v. State" on Justia Law