Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction for felony neglect of a dependent resulting in her death, holding that the trial court did not abuse its discretion in admitting evidence at trial that Defendant had, on prior occasions, used a pillow to muffle his infant daughter's crying.On appeal, Defendant argued that the evidence of prior pillow incidents was inadmissible under Ind. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the State may introduce other-bad-acts evidence to show lack of accident only when the State has reliable assurance that an accident defense will be raised or after the defendant places the accident at issue on trial; (2) in the instant case, because the State was reliably assured that Defendant would raise an accident defense, it could properly introduce the Rule 404(b) evidence; and (3) there was no abuse of discretion in admitting that evidence because the evidence's prejudicial effect did not outweigh its probative value. View "Fairbanks v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony resisting, holding that the challenged instruction in this case potentially misled the jury as an incorrect statement of law but that the jury charge, as a whole, cured the instructional defect.Specifically, the Court held (1) Defendant did not invite the alleged instructional error; (2) the challenged instruction misstated the mens rea and threatened to mislead the jury, and therefore, the use of the instruction is disapproved of going forward; but (3) the jury charge provided adequate instructions on the correct statutory elements and standard of proof, and the instructional defect was harmless. The Court then summarily affirmed Defendant’s convictions for felony battery and misdemeanor resisting, holding that Defendant failed to explain how instructional error affected his felony battery and misdemeanor resisting convictions. View "Batchelor v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt.Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt. View "Zanders v. State" on Justia Law

The Supreme Court reversed the judgment of the lower courts denying Appellant’s petition for post-conviction relief on the basis that his attorney provided deficient performance that prejudiced him, holding that counsel rendered ineffective assistance to Appellant by failing to properly advise him about the immigration consequences of a misdemeanor guilty plea.Appellant pleaded guilty to stealing less than twenty dollars of merchandise from Walmart without realizing that his guilty plea made him a deportable felon under federal immigration law. Appellant sought post-conviction relief, alleging ineffective assistance of counsel. The lower courts denied relief. The Supreme Court reversed, holding (1) Appellant’s attorney rendered constitutionally deficient performance as a matter of law by independently marking “N/A” next to the citizenship advisement on the standard advisement of rights from before inquiring into Appellant’s citizenship status; and (2) counsel’s deficient performance prejudiced Appellant. View "Bobadilla v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained after Defendant was stopped for speeding, holding that there was reasonable suspicion for a traffic stop under the circumstances.At issue was whether there was reasonable suspicion for the traffic stop where the police officer’s calibrated radar indicated that an oncoming vehicle was speeding and the officer verified the radar speed exceeded the posted speed limit but failed to document the excessive speed. The trial court denied Defendant’s motion to suppress on the basis that the officer’s stop of Defendant was based upon his observation that a traffic infraction was being committed. The Supreme Court affirmed, holding that the traffic stop passed muster under both the United States and Indiana Constitutions. View "Marshall v. State" on Justia Law

At issue in this case was whether to extend the holding in Tumulty v. State, 666 N.E.2d 394 (Ind. 1996) that a adult criminal defendant cannot challenge the validity of his guilty plea on direct appeal to an agreed delinquency adjudication. The Supreme Court held in this case that before Juvenile may pursue an appeal he must first seek relief from the trial court under Trial Rule 60(B).Specifically, the Supreme Court held (1) juveniles cannot immediately challenge on direct appeal any errors concerning their agreed adjudication, but because juveniles are not eligible for post-conviction relief, before pursuing their constitutional right to appeal, they must first assert any claims of error concerning their agreed judgment in a request for post-judgment relief filed with the juvenile court; and (2) juveniles who seek that relief in post-judgment proceedings have a statutory right to counsel under Ind. Code 31-32. View "J.W. v. State" on Justia Law

Finding this to be a rare and exceptional criminal case, the Supreme Court reduced Defendant’s sentence pursuant to Appellate Rule 7(B), holding that the sentence imposed was inappropriate in light of Defendant’s offenses and character.Defendant pled guilty to multiple drug charges and admitted to being a habitual substance offender. The trial court sentenced Defendant to an aggregate sentence of thirty years to be served in the Indiana Department of Correction. The court of appeals affirmed. The Supreme Court granted Defendant’s petition to transfer and reduced Defendant’s sentence to the mandatory minimum of twenty-three years with the time remaining to be served in community corrections, holding that this was an exceptional case and that Defendant’s sentence was inappropriate given Defendant’s character and offenses committed. View "Livingston v. State" on Justia Law

The Supreme Court affirmed the order of the trial court granting Defendant’s petition for specialized driving privileges, holding that the proper venue for seeking relief when the petitioner “forfeits” driving privileges for life following a felony conviction for driving while suspended is the trial court in the petitioner’s county of residence.Petitioner, a resident of Adams County, was subject to a driver’s license suspension that was a lifetime forfeiture resulting from a felony conviction for driving while suspended as a habitual traffic violator. Petitioner petitioned the Adams Superior Court for specialized driving privileges (DSP), seeking relief that that suspension and two other suspensions. The superior court granted the SDP petition. The court of appeals reversed and remanded, holding that where the Noble Superior Court ordered the lifetime forfeiture, Petitioner was required to petition that court separately for SDP. The Supreme Court reversed, holding the lifetime forfeiture in this case was an administrative suspension rather than a court-ordered suspension, and therefore, Petitioner was required to seek relief in his county of residence rather than in the court that ordered the suspension. View "State v. Reinhart" on Justia Law

The Supreme Court affirmed Defendant’s conviction of murder and felony murder but remanded this matter for a more specific sentencing statement consistent with the dictates of Harrison v. State, 644 N.E.2d 1243, 1262 (Ind. 1995), holding that the sentencing statement did not meet the requirements of Harrison.Defendant pled guilty to the murder of Asenath Arnold and to felony murder for the death of Gary Henderson at the hands of Defendant’s accomplice. Defendant was sentenced to life without parole of the murder charge. The Supreme Court affirmed the convictions and sentence but remanded the matter for a new sentencing statement, holding (1) Defendant’s Miranda rights were not violated; (2) there was sufficient evidence to support the aggravating circumstance that made Defendant eligible for a life without parole sentence; (3) Defendant’s sentence of life with parole was appropriate; but (4) the sentencing statement did not comply with the dictates of Harrison. View "Schuler v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment finding Defendant guilty but mentally ill (GBMI), holding that the evidence led only to the conclusion that Defendant was insane when the crime was committed.Defendant was charged with murder. Defendant invoked the insanity defense and waived her right to a trial by jury. During the bench trial, three mental health experts testified that Defendant was legally insane at the time of the murder and could not appreciate the wrongfulness of her actions. The trial court rejected Defendant’s insanity defense and found Defendant guilty of GBMI, relying on evidence of Defendant’s demeanor in rendering its verdict. The court of appeals reversed, concluding that because of Defendant’s history of mental illness and the unanimous expert opinion, the demeanor evidence had no probative value. The Supreme Court vacated the court of appeals’ opinion and affirmed, holding (1) the fact-finder may discredit expert testimony and rely instead on other probative evidence from which to infer Defendant’s sanity; and (2) evidence of Defendant’s demeanor, taken together with the flaws in expert opinion testimony and the absence of a well-documented history of mental illness, supported the trial court’s rejection of Defendant’s insanity defense. View "Barcroft v. State" on Justia Law