Articles Posted in Supreme Court of Indiana

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Defendant carried a handgun as she battered a law enforcement officer and resisted law enforcement. Defendant was not charged with a firearm-related offense, but nonetheless, the State introduced her gun into evidence at trial. Defendant was found guilty of felony battery against a public safety official and resisting law enforcement. Defendant challenged the gun’s admission at trial. The Supreme Court affirmed, holding (1) res gestate did not survive the adoption of Indiana’s Rules of Evidence in 1994; and (2) under the Rules of Evidence, the trial court did not abuse its discretion admitting Defendant’s gun into evidence because the gun was relevant to Defendant’s aggressiveness, and the danger of unfair prejudice did not substantially outweigh its probative value. View "Snow v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for battery against a public safety official and resisting law enforcement, holding (1) as the Supreme Court held in Snow v. State, __ N.E. 3d __ (Ind. 2017), the trial court did not abuse its discretion in admitting into evidence the gun of Defendant’s girlfriend, who was also convicted of the same offenses; and (2) because Defendant failed to seek a separate trial or a limiting instruction he waived any argument that the gun’s admission denied him a fair trial, and there was no fundamental error in the trial court’s decision not to give a limiting instruction sua sponte. View "Harris v. State" on Justia Law

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When Defendant was stopped for a traffic violation, Defendant agreed to take a chemical test at a nearby police station. Defendant did not blow hard enough during the test, prompting the machine to print an “insufficient sample” warning. The law enforcement officer determined that Defendant had refused to take the test, which resulted in the suspension of Defendant’s driving privileges. The Supreme Court reversed, holding that the procedures promulgated by the Indiana State Department of Toxicology required the officer to administer a second test because there was no factual basis for the trooper’s determination that Defendant refused the chemical test. View "Hurley v. State" on Justia Law

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Indiana appellate courts reviewing the sufficiency of the evidence must apply the same deferential standard of review to video evidence as to other evidence unless the video evidence indisputably contradicts the trial court’s findings. The Supreme Court affirmed Defendant’s convictions for resisting law enforcement and battery to a law enforcement animal as class A misdemeanors, holding that the video evidence presented at trial did not indisputably contradict the testimony of five police officers, and there was other evidence that sufficiently established the elements of the crimes. The Supreme Court’s holding supplemented its standard of review for video evidence to add a narrow failsafe to prevent impermissible reweighing by appellate courts when reviewing video evidence. View "Love v. State" on Justia Law

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The Supreme Court held that evidence obtained after a search and seizure was obtained in violation of the Fourth Amendment and that the trial court erred in denying Defendant’s motion to suppress the evidence obtained as a result of the search and seizure. The trial court denied the motion to suppress, concluding that law enforcement officers had reasonable suspicion to approach and question Defendant after they received a call that someone of Defendant’s description had a handgun on him. The Supreme Court reversed, holding that the intrusion by the police was not reasonable in this case. View "Pinner v. State" on Justia Law

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Fifteen years after the Supreme Court affirmed Appellant’s conviction for murder, Appellant filed an amended petition for post-conviction relief, alleging that trial counsel rendered ineffective assistance. The post-conviction court denied relief on the merits. The Supreme Court reversed, holding that, in viewing the evidence without certain inadmissible hearsay statements, Appellant established grounds for relief by a preponderance of the evidence. Specifically, the Court held that counsel’s errors, which allowed the jury to consider the only evidence that identified Appellant as the shooter in determining his guilt or innocence, were sufficient to undermine confidence in the verdict rendered in this case. View "Humphrey v. State" on Justia Law

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The Supreme Court held that the “third-party doctrine,” which provides that police are not required to obtain a search warrant to gather information an individual has voluntarily relinquished to a third party, applies as to historical cell-site location information (CSLI). Defendant appealed his convictions on four robbery-related counts, arguing that the State violated his Federal and State Constitutional rights by obtaining historical cell-site location information (CSLI) from his cell-phone service provider and that a detective improperly testified as an expert witness regarding the CSLI. The Supreme Court affirmed, holding (1) under the Fourth Amendment, Defendant had no reasonable expectation of privacy in his cell-phone provider’s historical CSLI; (2) the Indiana Constitution does not prohibit police from taking reasonable actions like obtaining minimally intrusive historical CSLI from a service provider to prevent a criminal suspect from striking again; and (3) the detective sponsoring the CSLI at trial properly testified as a skilled witness. View "Zanders v. State" on Justia Law

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Defendant appealed his convictions for two counts of murder for which the trial court imposed consecutive life without parole sentences. The Supreme Court affirmed, holding (1) the evidence was sufficient to sustain the murder convictions; (2) the trial court properly found that the State proved the I.C. 35-50-2-9(b)(11) aggravator beyond a reasonable doubt; (3) the trial court did not abuse its discretion in admitting into evidence Defendant’s recorded phone calls made to a special agent, as the phone calls were not protected by Defendant's Sixth Amendment right to counsel; and (4) Indiana’s life without parole statutory sentencing scheme is constitutional. View "Leonard v. State" on Justia Law

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Defendant pleaded guilty to Class D felony theft. As part of his plea agreement with the State, Defendant agreed that he would be “precluded from asking for misdemeanor treatment.” At that time, trial courts could convert sentences only at the time of sentencing. In 2012, however, the General Assembly amended Ind. Code 35-50-2-7 by allowing sentences to be converted after they had been entered. In 2015, Defendant filed a petition seeking to convert his Class D felony to a Class A misdemeanor under section 35-50-2-7(d). The trial court granted the petition, vacated Defendant’s felony, and re-entered the conviction as a Class A misdemeanor. The Supreme Court reversed, holding that the legislative amendment did not alter the unambiguous terms of Defendant’s plea agreement, and therefore, the trial court exceeded its authority when it granted Defendant’s petition, circumventing the agreement’s terms. View "State v. Smith" on Justia Law

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The State charged Defendant with dealing in marijuana and maintaining a common nuisance. At some point, the State informed Defendant that it had a video recording of a controlled buy between him and a confidential informant (CI). The State offered Defendant’s public defender the opportunity to review the recording but would not allow Defendant himself to see the video. After Defendant unsuccessfully requested a copy of the recording, his counsel filed a motion to compel, arguing that Defendant’s personal review of the video was fundamental to preparing a defense. In response, the State claimed that the informer’s privilege allowed withholding the identity of the CI. The trial court denied the motion to compel. The Supreme Court reversed, holding (1) the State failed to make the threshold showing that the informer’s privilege applied in the first instance because it was unclear whether the video would actually reveal the informant’s identity; and (2) even if the State had made the threshold showing, Defendant carried his burden of proving an exception to the privilege because his review of the video was “relevant and helpful to his defense or [was] necessary for a fair trial.” View "Beville v. State" on Justia Law