Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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The Supreme Court reversed the judgment of the trial court denying Appellant's petition for expungement, holding that because the trial court may have denied the petition on the erroneous belief that Ind. Code 35-38-9-4(b)(3) rendered Defendant ineligible for expungement, remand was required.Appellant pled guilty to Class B felony conspiracy to commit burglary. After completing the terms of his probation without any violations and waiting the required three years, Appellant petitioned for expungement under section 35-38-9-4. The trial court denied the petition for expungement without explaining its reasoning. The Supreme Court reversed, holding (1) a trial court may consider facts incident to the conviction when evaluating an expungement petition; and (2) because the trial court did not articulate why it denied Appellant's petition, the case must be remanded with instructions for the court to reconsider its decision consistent with this opinion. View "Allen v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct but that it was not likely that Defendant was harmed by the misconduct.The juror at issue wrote "N/A," meaning not applicable, in response to jury questions on her jury questionnaire regarding her past criminal history and whether she had herself been a victim of a crime. The juror, however, had in fact been charged with a crime and had been the victim of domestic abuse. The court of appeals reversed the convictions, finding that the trial court erred in not finding that the juror's false answers amounted to gross misconduct that probably harmed Defendant. The Supreme Court reversed, holding that, despite the jurors gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of "dealing in a look-a-like substance," a level five felony under Ind. Code 35-48-4-4.6, holding that trial court did not err in denying Defendant's motion to suppress.At a casino, Defendant offered to sell a substance to a stranger, who reported the incident. Thereafter, a Gaming Enforcement Agent led Defendant to an interview room and proceeded to pat him down. The trial court admitted the evidence discovered as a result of the pat down. The Supreme Court affirmed, holding (1) the search and seizure proceeded within the bounds of the Fourth Amendment; and (2) therefore, the trial court did not abuse its discretion in admitting evidence obtained as a result. View "Johnson v. State" on Justia Law

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The Supreme Court reduced Defendant's aggregate sentence to 100 years, holding that Defendant's appellate counsel was ineffective on appeal by failing to bring an Appellate Rule 7(B) challenge to the appropriateness of Defendant's sentence.Defendant was convicted of two counts of murder, felony armed robbery, and felony conspiracy to commit criminal gang activity. The trial court sentenced Defendant to an aggregate sentence of 181 years. Defendant later sought post-conviction relief, arguing that, because he was a juvenile when he committed the crimes at issue, the criminal gang enhancement was unconstitutional as applied and that both his trial counsel and appellate counsel were ineffective. The post-conviction court denied Defendant's petition for relief. The Supreme Court revised Defendant's sentence downward to an aggregate 100 years, holding (1) Defendant's original sentence was not unconstitutional under the Eighth Amendment because the sentence was not subject to the requirements of Miller v. Alabama, 567 U.S. 460 (2012); but (2) Defendant's appellate counsel performed inadequately by failing to request appellate review of the sentence's appropriateness under Appellate Rule 7(B). View "Wilson v. State" on Justia Law

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The Supreme Court reversed Defendant's maximum 138-year sentence imposed for crimes Defendant committed as a juvenile and revised the sentence to a total sentence of eighty-eight years, holding that the 138-year sentence was inappropriate.Defendant was seventeen years old when he and two others committed murder in 1991. Defendant received an aggregate sentence of 138 years, which was the maximum possible term-of-years sentence. In 2016, Defendant filed a verified petition for post-conviction relief challenging the propriety of his sentence in light of the fact that he was a juvenile when he committed the crimes. The post-conviction court granted the petition and imposed an aggregate sixty-eight-year sentence. The Supreme Court affirmed the order granting relief and revisited its prior decision regarding the appropriateness of his sentence but revised the sentence to an aggregate term of eighty-eight years, holding (1) the doctrine of res judicata does not bar consideration of Defendant's appropriateness argument due to two major shifts in the law; and (2) Defendant's maximum term-of-years sentence imposed for crimes he committed as a juvenile was inappropriate. View "State v. Stidham" on Justia Law

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The Supreme Court reversed the order of the trial court denying Defendant's motion to dismiss his habitual offender enhancement, holding that Defendant's constitutional right to a speedy trial was violated by an extraordinary six-plus-year delay.Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual offender enhancement. The court granted the State permission to retry the habitual offender allegation, but it would be nearly six and a half years before Defendant was retried. Before his retrial, Defendant filed a motion to dismiss, alleging a violation of Ind. Crim. R. 4(C) and his constitutional right to a speedy trial. The court denied Defendant's motion to dismiss. After a trial, a jury found that Defendant was a habitual offender. The Supreme Court reversed, holding (1) Defendant was not entitled to discharge under Rule 4(C) because that rule does not apply to the retrial of a habitual offender allegation; but (2) Defendant's constitutional right to a speedy trial was violated, and therefore, Defendant was entitled to relief. View "Watson v. State" on Justia Law

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In these consolidated appeals, the Supreme Court held that under the clear and unambiguous language of several relevant statutes, a juvenile court did not have subject matter jurisdiction to waive two individuals into adult criminal court because neither fit the definition of a "child" at the time their respective delinquency petitions were filed.The State filed juvenile delinquency petitions against D.P. and N.B. for committing, when they were under the age of eighteen, what would be felony child molesting if committed by an adult. Both individuals were twenty-one or older at the time the delinquency petitions were filed. The State requested that D.P. and N.B. be waived into adult criminal court, and D.P. and N.B. moved to dismiss their respective cases for lack of subject matter jurisdiction. The motion to dismiss was denied in D.P.'s case and was granted in N.B.'s case. The Supreme Court affirmed the juvenile court's dismissal in N.B. and reversed in D.P. and remanded with instructions to grant the motion to dismiss, holding that a juvenile court does not have subject matter jurisdiction to waive an alleged delinquent offender into adult criminal court if the individual is no longer a "child." View "D.P. v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for two counts of attempted murder, holding that Defendant's actions, despite their proximity in space and time, amounted to two distinct, chargeable offenses.Defendant fired five to six shots in rapid succession at two victims sitting in an adjacent vehicle. Defendant seriously injured one of the victims. At issue was whether Defendant was guilty of one count of attempted murder for the single act of shooting or two counts of attempted murder, one count for each victim. The jury found Defendant guilty of two counts of attempted murder. On appeal, Defendant argued that his two convictions violated the state constitutional protection against double jeopardy. The Supreme Court affirmed, holding that because the evidence was sufficient to prove that Defendant fired his weapon multiple times with the dual purpose of intentionally killing both victims the multiple shots Defendant fired amounted to two chargeable offenses. View "Powell v. State" on Justia Law

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The Supreme Court expressly overruled the constitutional tests set forth in Richardson v. State, 717 N.E.2d 32 (Ind. 1999), in resolving claims of substantive double jeopardy and adopted an analytical framework that applies the statutory rules of double jeopardy.The Richardson court adopted a comprehensive analytical framework constituting of a statutory elements test and an actual evidence test for deciding all substantive double jeopardy claims under Ind. Const. art. I, 14. Application of the tests, however, proved largely untenable, resulting in a patchwork of conflicting precedent and inconsistent standards. Defendant in this case was convicted of several offenses for leaving the scene of an accident after striking and injuring the victim while driving drunk. The Supreme Court overruled Richardson and adopted a framework that applies when a defendant's single act or transaction implicates multiple criminal statutes. The Court then held that Defendant's multiple convictions violated the statutory rules of substantive double jeopardy. View "Wadle v. State" on Justia Law

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The Supreme Court reversed the decision of the trial court denying Defendant's motion for discharge under Indiana Criminal Rule 4(C), holding that, under the circumstances of this case, Defendant was entitled to discharge.After Defendant successfully suppressed certain evidence the State filed an interlocutory appeal. Rather than request a stay of the proceedings the State asked for a continuance during the pendency of its appeal. Only after Defendant moved for a discharge did the State belatedly asked for a stay of the proceedings. The trial court granted the request and denied Defendant's renewed motion for discharge. The Supreme Court reversed, holding (1) Rule 4(C)'s clock continued to tick until the State formally moved for a stay of the proceedings, and this time continued to count against Rule 4's one-year limitation in prosecuting the charged crimes; and (2) the State exceeded the one-year limitation. View "Battering v. State" on Justia Law