Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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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

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of four felony counts and dismissing a firearm enhancement sua sponte, holding that the State failed to meet its burden to show that the trial court's implied finding of waiver and subsequent sua sponte dismissal of the firearm enhancement were contrary to law.After a trial, the jury found Defendant guilty of four felony counts, including aggravated battery as a Level 3 felony. After the trial court accepted the verdicts and excused the jury the State raised a firearm enhancement. The trial court responded that the enhancement was dismissed as a matter of course. After Defendant was sentenced the State appealed, arguing that the trial court abused its discretion by dismissing the firearm enhancement. The Supreme Court affirmed, holding that the State waived the enhancement and that the trial court's sua sponte dismissal of the firearm enhancement was not contrary to law. View "State v. Brake" on Justia Law

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The Supreme Court exercised its constitutional authority to revise Defendant's sentence, holding that the trial court did not abuse its discretion when sentencing Defendant but that, in Defendant's circumstances, her sentence was inappropriate.Defendant pleaded guilty to several drug-related offenses. The Supreme Court sentenced Defendant to an aggregate sentence of twenty-four-and-one-half years. The Supreme Court exercised its authority under Ind. Const. art. VII, 4 to review and revise Defendant's sentence, holding that, due to Defendant's youth, her difficult childhood, and her non-violent criminal history, her aggregate sentence was inappropriate. The Court remanded the case to the trial court to issue a revised sentencing order reflecting an aggregate sentence of eighteen years. View "Mullins v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentence for voluntary manslaughter, holding that the trial court did not abuse its discretion in imposing the sentence and that the sentence was not inappropriate given the nature of the offense and Defendant's character.Defendant was charged with murder. The State later added an enhancement for knowingly or intentionally using a firearm in commission of the offense. The defense petitioned the trial court to include a jury instruction on the lesser-included offense of voluntary manslaughter. The trial court granted the petition, and the jury found Defendant guilty of voluntary manslaughter but not murder. During a bench trial on the firearm enhancement's applicability to Defendant's manslaughter conviction, the judge made multiple comments indicating he believed Defendant should have been convicted of murder. The trial court sentenced Defendant to forty-five years in prison. On appeal, Defendant argued that the trial judge impermissibly increased his sentence based on the judge's beliefs about the case. The Supreme Court affirmed, holding (1) the judge's comments disagreeing with the jury's verdict were insufficient to taint the sentencing decision; and (2) the sentence was not inappropriate in light of Defendant's character and the nature of the crime. View "McCain v. State" on Justia Law

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The Supreme Court reversed the judgment of the trial court suppressing blood test results obtained the morning of a vehicle collision, holding that the blood-draw search warrant application satisfied the filing requirement under Ind. Code 35-33-5-2(a).Defendant caused a head-on collision when he drove the wrong way on a freeway. Defendant filed a motion to suppress blood test results obtained the morning of the accident, arguing that Ind. Code 35-33-5-2 and his constitutional rights against unreasonable search and seizure were violated when the arresting state trooper failed properly to file a probable cause affidavit to obtain a blood-test search warrant. The trial court granted the motion, concluding that a copy of the probable cause affidavit was not properly "filed" until a few hours after it had been presented to the warrant-authorizing judge and swiftly executed. The Supreme Court reversed, holding that the blood-draw search warrant application satisfied the filing requirement under section 35-33-5-2(a) because (1) the warrant-authorizing judge certified that the affidavit had been properly filed with her when the search warrant was issued; and (2) even if the affidavit was filed a few hours late it was still valid under Indiana's substantial compliance filing doctrine. View "State v. Ryder" on Justia Law

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The Supreme Court reversed Defendant's conviction for attempted murder and carrying a handgun without a license, holding that the trial court erred in instructing the jury on self-defense, and the instructional error was not harmless.During trial, Defendant asserted that he shot Derek Gilbert, who was intoxicated and aggressive, to protect his and his son's lives. The court instructed the jury that Defendant could not assert self-defense if he committed a crime that was "directly and immediately related" to his confrontation with Gilbert. The Supreme Court reversed the conviction, holding (1) the jury instruction diluted the standard set forth in Mayes v. State, 744 N.E.2d 390 (Ind. 2001), that "there must be an immediate causal connection between the crime and the confrontation"; and (2) this instructional error was not harmless. View "Gammons v. State" on Justia Law

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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