Justia Criminal Law Opinion Summaries

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

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

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

Defendant entered a field sobriety checkpoint and was asked if he had been drinking. Defendant admitted that he had. The officer administered some field sobriety tests and ultimately arrested Defendant. Defendant was charged with operating while intoxicated and operating a vehicle with an alcohol concentration of at least .08 but less than .15 grams of alcohol per 210 liters of breath. During trial, Defendant’s counsel objected to the officer’s testimony about him asking Defendant if he had been drinking and Defendant’s response based on a Miranda violation. In response, the State argued that a Miranda warning was not necessary. The trial court then entered an order suppressing any statements made by Defendant, as well as any evidence obtained thereafter. On appeal, the Court of Appeals, dismissed the appeal, ruling that the State had no statutory authority to appeal because Defendant never filed a written motion to suppress and because the order suppressing the evidence was issued during trial. The Supreme Court granted transfer and reversed the trial court’s suppression order, holding (1) the State may appeal from the trial court’s order granting Defendant’s motion to suppress; and (2) Miranda warnings are not required in circumstances such as these, where a defendant is briefly detained at a public sobriety checkpoint. View "State v. Brown" on Justia Law

Defendant pleaded guilty to two counts of attempted murder as class A felonies and two counts of attempted robbery resulting in serious bodily injury also as class A felonies. Defendant was sentenced to 100 years’ imprisonment with sixty years suspended to probation for an aggregate sentence of forty years executed. Defendant later filed a petition for post-convcition relief, arguing that his guilty plea was not entered knowingly, intelligently, and voluntarily, that the plea lacked a factual basis, and that the trial court erred in accepting the plea. The Supreme Court reversed, holding that Petitioner demonstrated by a preponderance of the evidence that the post-conviction court erred in denying his petition for relief because, at the time Petitioner entered the plea, he also professed his innocence. View "Ellis v. State" on Justia Law

Defendant was convicted of two counts of Class B felony burglary and adjudicated a habitual offender. The trial court sentenced Defendant to an aggregate sentence of thirty-three years. Defendant appealed, arguing that his sentence was inappropriate under Indiana Appellate Rule 7(B). The court of appeals affirmed. The Supreme Court granted transfer and revised Defendant’s sentences so that he received an aggregate sentence of sixteen years, holding that an aggregate sentence of thirty-three years was inappropriate in this case. In all other respects the Court summarily affirmed the Court of Appeals’ decision. View "Wampler v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder. Defendant was sentenced to life without parole. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court did not commit fundamental error when it did not find, sua sponte, that Defendant had an intellectual disability, precluding a life without parole sentence, even though Defendant's trial counsel withdrew the petition to determine whether he had the disability; (2) Defendant’s life without parole sentence was proportionate to the offense and thus did not violate Article 1, Section 16 of the Indiana Constitution; and (3) Defendant’s sentence was appropriate pursuant to Indiana Appellate Rule 7(B). View "Shoun v. State" on Justia Law

Defendant was charged with felony possession. Defendant filed a motion to suppress, arguing that the police violated the Fourth Amendment and Article I, Section 11 of the Indiana Constitution when they opened his car door “to check on [Defendant’s] welfare.” The trial court denied the motion and, after a bench trial, convicted Defendant of misdemeanor possession of cocaine. The court of appeals affirmed, concluding that the police’s act of opening Defendant’s door was constitutionally permissible as a reasonable community caretaking function. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed, holding that the police’s warrantless search of Defendant was constitutionally permissible, as the officer had an objectively reasonable basis to open the door and check on Defendant’s well-being. View "Cruz-Salazar v. State" on Justia Law

Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law

Appellant pled guilty to possession of cocaine as a class D felony. In 2007, Appellant filed a pro se petition for post-conviction relief alleging ineffective assistance of counsel. The court summarily denied Appellant’s petition. In 2015, by counsel, Appellant filed a verified motion for leave to amend his petition for post-conviction relief and a verified motion for relief from the 2007 order that summarily denied his petition for post-conviction relief, arguing, inter alia, that his post-conviction petition was not referred to the State Public Defender and that his lack of education and cognitive deficiencies impacted his ability to represent himself. The post-conviction court determined that it would reinstate Appellant’s 2007 petition for post-conviction relief. The Supreme Court affirmed, holding that because Appellant’s 2007 petition for post-conviction relief was not referred to the State Public Defendant as required by the Post-Conviction Rules, and in light of Petitioner’s educational and cognitive deficiencies, the post-conviction court did not err in granting Appellant’s motion for relief from judgment so that he could seek meaningful post-conviction review. View "State v. Collier" on Justia Law