Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Indiana
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The Supreme Court affirmed the order of the trial court suppressing incriminating statements Defendant made immediately following a polygraph examination, holding that before excluding evidence as a Trial Rule 37 discovery sanction, a trial court must find that the exclusion is the sole remedy available to avoid substantial prejudice and that the sanctioned party's culpability reflects an egregious discovery violation.Defendant was interviewed at the police department as part of an investigation as to whether he sexually abused a minor. Defendant agreed to sit for a polygraph and agreed that the results of the polygraph would be admissible if the State charged him with a crime. The State subsequently charged Defendant with child molesting. Defendant moved to suppress the polygraph results and his related statements, arguing that his statements were not voluntary or reliable. The trial court denied the motion. On the eve of trial, the deputy prosecutor disclosed that the officer who administrated the exams had unilaterally changed the exam to a "non-stipulated," inadmissible investigatory examination. The judge suppressed the incriminating statements as a discovery sanction. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court's order enforced Trial Rule 37 within the limits set forth in this opinion. View "State v. Lyons" on Justia Law

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The Supreme Court affirmed the judgment of the trial court excluding the opinion testimony from three of Defendant's family members regarding the victim's untruthful character, holding that the trial court erred in excluding the opinion testimony but that the error was harmless.Defendant was charged with several felony child molestation counts and one count of felony incest for molesting his minor daughter. Before trial, Defendant requested to call three relatives as witnesses to testify about the opinion of the victim's character for untruthfulness. The trial court excluded the testimony on the grounds that Defendant had not established a proper foundation. After trial, the jury found Defendant guilty of felony child molesting. The Supreme Court affirmed, holding that the trial court erred in excluding the testimony of one witness for lack of foundation, but the error was harmless. View "Hayko v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of murder, felony robbery resulting in serious bodily injury, and two counts of criminal confinement and his sentence of life without parole for the murder conviction, holding that Defendant was not entitled to relief on his allegations of error.Defendant, a gang leader, supervised and participated in the torture and brutal killing of member of the gang that other members believed was a police snitch. Once the victim was dead, Defendant oversaw cleaning up the crime scene and then hid the body. The Supreme Court affirmed the judgment in its entirety, holding (1) there was sufficient evidence both to find that Defendant was a "major participant" in the victim's murder and to support two of the statutory aggravators; (2) the trial court did not abuse its discretion in declining to instruct the jury as proposed by Defendant; and (3) the record supported the other aggravating factors not relating to the life without parole sentence. View "Owen v. State" on Justia Law

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The Supreme Court affirmed Defendant's sentence of life imprisonment without the possibility of parole (LWOP) in connection with his conviction for the murder and burglary of his ex-girlfriend, holding that Defendant's LWOP sentence was not inappropriate.On appeal, Defendant argued that the jury failed to meet all statutory prerequisites for an LWOP sentence by failing to determine that the aggravating circumstances outweighed the mitigating circumstances and that his sentence was inappropriate in light of the mental illness he was suffering when he committed the crimes. The Supreme Court affirmed, holding (1) the jury's LWOP recommendation reflected its determination that the aggravating circumstances outweighed the mitigating circumstances; and (2) the LWOP sentence was not inappropriate. View "Oberhansley v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal of his sentence, holding that Appellant's written plea agreement with the State unambiguously waived his right to appeal his sentence.Appellant pled guilty to four theft-related offenses in exchange for a more lenient sentence. Both Appellant and his attorney signed a three-page plea agreement with the State in which Appellant waived his right to appeal his sentence. Appellant sought to appeal his sentence despite his plea agreement. The Supreme Court dismissed the appeal, holding (1) Appellant waived his right to appeal his sentence; and (2) if Appellant's guilty plea was not knowing and voluntary because the trial judge's misstatements misled him as to which rights he was waiving, Appellant's remedy was to vacate his conviction through post-conviction relief proceedings. View "Davis v. State" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals affirming the trial court's denial of Appellant's post-conviction petition for permission to file a belated notice of appeal, holding that the appeal should be allowed to proceed.In 1999, Appellant pleaded guilty to burglary, robbery, rape, and criminal confinement, all felonies. In 2021, Appellant filed a petition for post-conviction relief seeking to file a belated notice of appeal under Rule 2 and claiming that when he signed his guilty plea there was no advisement that he had the right to appeal his sentence and that he did not learn of his ability to appeal until that that year. The trial court denied the petition without holding an evidentiary hearing, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant was not at fault in failing to file a timely notice of appeal and was diligent in pursuing his belated notice of appeal. View "Leshore v. State" on Justia Law

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In this interlocutory appeal, the Supreme Court affirmed the judgment of the criminal court entering an order in limine excluding from evidence the juvenile court's order in a child in need of services (CHINS) proceedings, holding that the trial court did not abuse its discretion by excluding the CHINS order.The Department of Child Services (DCS) filed a petition alleging that E.H., who was less than fourteen years old, was a CHINS. The juvenile court denied the petition after a fact-finding hearing. After further investigation, the State charged Defendant with Level 5 felony battery resulting in bodily injury to E.H. When Defendant sought to introduce at trial the CHINS order as evidence that someone else likely injured E.H. the State filed a motion to exclude that evidence in limine. The trial court granted the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by excluding the CHINS order under the circumstances of this case. View "Means v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of involuntary manslaughter, holding that the trial court violated Ind. Trial Rule 47(D) by denying defense counsel the opportunity to voir dire prospective jurors directly and that the error was not harmless.As the State acknowledged at oral argument, the parties agreed at the time of this opinion, that the trial court violated Trial Rule 47(D) during voir dire when it prohibited defense counsel from questioning prospective jurors directly. The Supreme Court reversed Defendant's conviction and remanded the case for a new trial, holding (1) the trial court went beyond setting reasonable limits on voir dire; and (2) the error was not harmless. View "Doroszko v. Indiana" on Justia Law

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The Supreme Court affirmed Defendant's conviction of the murder of her ten-year-old stepdaughter, S.C., and her sentence of life without parole, holding that the State sufficiently carried its evidentiary burden to disprove the existence of "sudden heat" because of a lack of adequate provocation, accompanied by a sustained cooling-off period.At issue was whether the State failed to satisfy its evidentiary burden in negating the mitigating factor of "sudden heat," the necessary condition to reduce Defendant's conviction to voluntary manslaughter. The Supreme Court affirmed Defendant's conviction and life-without-parole sentence, holding that the State satisfied its evidentiary burden in negating the mitigating factor and voluntary manslaughter requirement of sudden heat. View "Carmack v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for murder and two counts of attempted murder, holding that the jury permissibly resolved the issues of fact raised on appeal against Defendant.On appeal, Defendant argued that the evidence did not support his convictions because the jury could not have found beyond a reasonable doubt that he was the shooter at issue. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to identify Defendant as the shooter; (2) the doubts Defendant raised about the evidence presented factual disputes that the jury was entitled to resolve; and (3) the jury could reasonably have resolved an inconsistency in the evidence in the State's favor. View "Young v. State" on Justia Law