Justia Criminal Law Opinion Summaries

Defendant was charged with felony attempted murder and felony aggravated battery. The trial judge adjudged Defendant guilty but mentally ill on both counts. Defendant appealed, arguing in part that the State did not present sufficient evidence that he had the specific intent to kill, as required for attempt murder. The court of appeals reversed Defendant’s attempted murder conviction and remanded for a new trial. The State sought transfer. The Supreme Court granted transfer and reversed Defendant’s conviction for attempted murder, holding that a remand was required for the trial court to reconsider the case under the correct legal standard to the existing evidence. View "Miller v. State" on Justia Law

The Supreme Court reversed Defendant’s conviction of Class A misdemeanor possession of a handgun with a license, holding that the State’s detention and search of Defendant was unreasonable under Ind. Const. art. I, 11.The court of appeals affirmed Defendant’s conviction, concluding that Defendant’s behavior in evading police in a high crime area was sufficient to give rise to a reasonable suspicion that crime was afoot, especially where the officers believed Defendant was a truant. The Supreme Court vacated the court of appeals’ decision, holding that the police’s investigatory stop, detention, and search of Defendant violated Defendant’s constitutional rights because, although Defendant’s actions were “suspicious,” at the time police moved to detain Defendant, police did not have a reasonable suspicion that he had engaged in or was about to engage in any criminal conduct. View "Jacobs v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of bestiality. On appeal, Defendant argued that the trial court abused its discretion when it admitted evidence of his admissions of guilt, in violation of the corpus delicti rule. The Court of Appeals reversed, concluding that the State was required to prove penetration of the dog’s sex organ by a male sex organ before it could admit Defendant’s statement into evidence. The Supreme Court granted transfer, thus vacating the court of appeals opinion, holding that the State presented independent evidence that provided an inference that Defendant committed bestiality, and therefore, the trial court properly found that the corpus delicti rule was satisfied and admitted Defendant’s confessions into evidence. View "Shinnock v. State" on Justia Law

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

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

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

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

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

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

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