Justia Criminal Law Opinion Summaries

Thomas Hale appealed his conviction for dealing in methamphetamine, on the sole grounds that the trial court abused its discretion in failing to grant him, at public expense, depositions of two State’s witnesses. After review, the Indiana Supreme Court found that prior precedent compelled the Court to agree with Hale and reverse his conviction. The Court took the opportunity of this case to provide guidance as to how trial courts should address such motions in the future. View "Hale v. Indiana" on Justia Law

Defendant was convicted of four traffic offenses related to his driving while intoxicated and his lack of a driver’s license. Defendant’s trial took place almost three years after his arrest. On appeal, Defendant argued that the trial court erred in denying his Ind. R. Crim. P. 4(C) motion for discharge for delay. Rule 4(C) provides that a defendant may not be held to answer a criminal charge for greater than one year except in certain circumstances. The Supreme Court reversed the denial of Defendant’s motion for discharge, holding that, under the circumstances of this case, Defendant was entitled to discharge pursuant to Rule 4(C). Remanded to the trial court to grant the motion pursuant to Rule 4(C). View "Allen v. State" on Justia Law

After a jury trial, Defendant was found guilty of domestic battery as a level 6 felony and battery as a level 6 felony. The level 6 battery conviction arose from Defendant’s assault on a woman whose brother had previously been married to Defendant’s aunt. The trial court sentenced Defendant to two years for each conviction to be served consecutively. The Supreme Court reversed the trial court’s judgment with respect to Defendant’s level 6 battery conviction, holding that the sister of a brother who was once married to Defendant’s aunt is not a “family or household” member within the meaning of the statute elevating misdemeanor battery to a level 6 felony. Remanded. View "Suggs v. State" on Justia Law

Appellant pleaded guilty to two counts of murder, one count of class A felony robbery, and one count of class B felony burglary for crimes he committed when he was thirteen years old. Appellant was sentenced to an aggregate term of 170 years imprisonment. Beginning in 1991, Appellant attempted to obtain his trial court transcripts to prepare a petition for post-conviction relief (PCR), but his requests were denied until 2006 when the trial court ultimately granted Appellant’s request for transcripts. When he still had not received the transcript of the plea hearing, he withdrew his post-conviction relief petition. In 2010, Appellant moved to compel compliance with the trial court’s order for transcripts, but the trial court denied the petition because Appellant’s PCR petition had been withdrawn. In 2011, Appellant again filed a pro se PCR petition. In 2015, Appellant filed a petition for permission to file a belated appeal. The trial court denied the petition. Appellant now asked the Supreme Court to permit him to file a belated notice of appeal to appeal his sentence. The Supreme Court reversed, holding that, under the unique circumstances of this case, Appellant should be permitted to file a belated notice of appeal. View "Sanford v. State" on Justia Law

After a jury trial, Defendant was convicted of dealing in a narcotic drug within 1,000 feet of school property, a class A felony, and of being a habitual substance offender. The Supreme Court affirmed, holding (1) Defendant’s claim that he was a victim of “sentencing factor manipulation” was unavailing because “sentencing factor manipulation” was inapplicable to the charges against him; (2) Defendant waived his claim that the jury verdict was not unanimous; (3) the trial court did not err in admitting redacted letters Defendant wrote to potential witnesses from prison; (4) there was sufficient evidence to support the conviction; and (5) the trial court was within its discretion in ordering Defendant to serve a sentence of forty years for felony dealing. View "Bowman v. State" on Justia Law

Defendant was charged with two D-felony counts of strangulation and two counts of domestic battery, one of which was elevated to a D-felony based on a prior domestic battery conviction. Defendant moved to bifurcate the D-felony domestic battery charge. The jury found Defendant guilty of the misdemeanor domestic battery and not guilty of the strangulation charges. The judge then asked Defendant’s counsel whether Defendant would like to waive his right to a jury trial on the D-felony domestic battery charge. Defendant remained silent while his attorney told the judge that Defendant intended to proceed as a bench trial on the second phase of the bifurcated trial. After a bench trial on the second phase Defendant was found guilty of the D-felony domestic battery. Defendant appealed, arguing that he did not validly waive his state and federal constitutional jury trial rights. The Supreme Court reversed Defendant’s conviction for D-felony domestic battery, holding that the trial court committed fundamental error by proceeding to trial absent personal waiver of his constitutional jury trial right by Defendant himself. Remanded for a new trial. View "Horton v. State" on Justia Law

After a jury trial, Defendant was found guilty of battery as a class A misdemeanor. Under the provisions of Ind. Code 35-38-1-7.7(a), the trial court also determined that Defendant committed a crime of “domestic violence,” which determination rendered Defendant ineligible to possess a firearm. Defendant appealed, arguing, in part, that the firearm restriction amounted to additional punishment above the statutory maximum for misdemeanor battery, and because the facts supporting the enhancement were not submitted to a jury, the determination violated Defendant’s Sixth Amendment right to trial by jury. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to trial by jury; and (2) the evidence was sufficient to sustain the determination that Defendant committed a crime of domestic violence. View "Hitch v. State" on Justia Law

Defendant pleaded guilty to murdering Stephanie Kirk. Following a sentencing hearing, the trial court sentenced Defendant to death. Defendant appealed his death sentence. The Supreme Court affirmed, holding (1) there was sufficient evidence to prove beyond a reasonable doubt that Defendant murdered Kirk while committing criminal deviate conduct; (2) the trial court did not commit fundamental error when it allowed the State to amend the charging information; (3) the trial court did not abuse its discretion in weighing the aggravating and mitigating circumstances in sentencing Defendant to death; and (4) Defendant’s sentence was not inappropriate in light of the nature of his offense and what the record revealed about his character. View "Gibson v. State" on Justia Law

In 1998, Appellant committed child molesting in Indiana. Appellant was released in 2006 and completed parole the next year. In 2009, Appellant moved to Iowa, where he was subject to a registration requirement. When Appellant moved back to Indiana in 2013, the State notified him that he was required to register as a sex offender. Appellant sought removal from the registry. The trial court denied the motion. On appeal, Appellant argued that because he committed his offense six years prior to the passage of Indiana’s Sex Offender Registry Act (SORA), application of SORA to him violated the Ex Post Facto Clause of the Indiana Constitution. The Supreme Court affirmed, holding that because Appellant was already under an obligation to register in another jurisdiction and Ind. Code 11-8-8-5(b)(1) and -19(f) do not impose any additional punishment on him, there was no ex post facto violation. View "Ammons v. State" on Justia Law

In 2013, Defendant was charged with second degree murder for the death of a toddler that occurred in 1977. During a bench trial, the court admitted into evidence an autopsy report. The autopsy was performed by a pathologist who was unavailable to testify at trial. In addition to the autopsy report, the State called a forensic pathologist to testify regarding his independent opinion of the child’s death and injuries based on the autopsy report. The trial court found Defendant guilty of second degree murder. Defendant was sentenced to life imprisonment under the relevant sentencing statutes in 1977. The Supreme Court affirmed, holding (1) because the autopsy report was not testimonial, Defendant’s confrontation right was not violated when the report was admitted into evidence or when the surrogate pathologist testified regarding the information detailed in the autopsy report; (2) the delay between the murder of the child and Defendant’s prosecution did not violate Defendant’s due process rights; and (3) even if the trial court erred at sentencing by taking into consideration the current sentencing scheme that was inapplicable in this case, the error was harmless. View "Ackerman v. State" on Justia Law