Justia Criminal Law Opinion Summaries

Defendant was arrested for suspected murder. During Defendant’s pre-interrogation with his lawyer, police officers and a prosecutor eavesdropped as Defendant and his attorney discussed the location of evidence and defense trial strategy. Defendant was charged with murder. The officers involved in the investigation invoked the Fifth Amendment in response to all questions related to the eavesdropping, thus preventing Defendant and the court from learning the identity of the eavesdroppers and what they had overhead. Before trial, the trial court ordered blanket suppression of trial testimony from any witness who pleaded the Fifth. The State appealed the blanket suppression ruling. The Court of Appeals reversed the pretrial blanket suppression. The Supreme Court granted transfer, thereby vacating the opinion of the Court of Appeals, holding that prospectively imposing blanket suppression of all testimony from witnesses pleading the Fifth Amendment is inappropriate because a presumption of prejudice, rebuttable only by proof beyond a reasonable doubt, adequately protects Defendant from prejudice caused by the officers’ eavesdropping and their assertion of the Fifth Amendment privilege. Remanded for a determination as to whether the State has proven beyond a reasonable doubt an independent source for each presumptively tainted witness’s testimony without implicating the witness’s Fifth Amendment privilege and without derogating Defendant’s right of confrontation. View "State v. Taylor" on Justia Law

Defendant was convicted of class B felony dealing in methamphetamine (by delivery) (Counts I and II), one count of class B felony dealing in methamphetamine (by manufacture) (Count III), and one count of class D felony possession of precursors with intent to manufacture methamphetamine (Count IV). The sentences for Counts III and IV were imposed to run concurrently with each other but consecutive to the sentences on Counts I and II. Defendant received an aggregate sentence of thirty-two years. The Court of Appeals affirmed. The Supreme Court reversed Defendant’s sentences on Counts III and IV to run concurrently with his sentences on Counts I and II, for an aggregate sentence of sixteen years, holding that, under the particular circumstances of this case, the aggregate sentence of thirty-two years was inappropriate. View "Eckelbarger v. State" on Justia Law

After a jury trial, Defendant was convicted of murdering four people. Defendant was sentenced to life without parole for each of the four counts of murder, with the sentences to run consecutively. On appeal, Defendant challenged the sufficiency of the evidence to convict him of four murders. This appeal came directly to the Supreme Court because a sentence of life without parole was imposed. The Supreme Court affirmed the judgment of the trial court, holding that the State presented ample evidence that Defendant committed the four murders. View "Sallee v. State" on Justia Law

After a jury trial, Defendants, a married couple, were each convicted of involuntary manslaughter. After they were sentenced, Defendants filed a motion to correct error seeking a mistrial based on one juror’s affidavit describing the conduct of an alternate juror during the jury’s deliberations. The trial court denied the motion. The Court of Appeals affirmed the convictions. The Supreme Court granted transfer, consolidated the cases, and reversed the convictions, holding (1) the juror’s affidavit established that the alternate juror’s participation in jury deliberations was an external influence that pertained to the case, which showings resulted in a presumption of prejudice to Defendants; and (2) the State did not rebut the presumption by showing that the jury was nonetheless impartial, and therefore, a new trial is required. Remanded. View "Wahl v. State" on Justia Law

Defendant was charged with twelve counts of various sex offenses. The charges arose from allegations made by three young girls. While Defendant was in jail awaiting his guilty plea hearing, he wrote an “intimidating and coercive” letter to the mother of one of the child victims. As a result of this letter, Defendant was charged with felony attempted obstruction of justice. The trial court found Defendant guilty of the charge and sentenced him to 600 days. The Supreme Court affirmed Defendant’s conviction and sentence for attempted obstruction of justice, holding (1) sufficient evidence supported the conviction; and (2) the trial court failed to properly consider Defendant’s participation in various program while incarcerated as a mitigating factor, but the error was harmless. View "McElfresh v. State" on Justia Law

Defendant was convicted of C-felony “corrupt business influence,” the formal name of the Indiana Racketeer Influenced and Corrupt Organizations (RICO) Act, for his involvement in three armed robberies during the course of a month. Defendant appealed, arguing that the State presented insufficient evidence to support his conviction for corrupt business influence because the State failed to prove that his actions posed a threat of “continued” criminal activity. The court of appeals agreed and reversed Defendant’s corrupt business influence conviction. The Supreme Court granted transfer and affirmed Defendant’s conviction for corrupt business influence, holding (1) continuity is not required for a corrupt business influence conviction, but continuity is relevant to whether the incidents were “not isolated,” which is an element of the definition; and (2) in this case, there was sufficient evidence that Defendant’s crimes were not isolated. View "Jackson v. State" on Justia Law

After a jury trial, Defendant was convicted of murder, attempted murder, felony murder, and related crimes. The trial court imposed life without parole for the murder conviction and a term of years for the remaining convictions. Defendant appealed, arguing that the trial court’s remark to the jury regarding cell tower towers and sites deprived him of a fair trial by vouching for the credibility of the State’s evidence and thereby discrediting his alibi defense. The Supreme Court affirmed the convictions and sentences, holding that the judge’s comment did not amount to fundamental error requiring reversal of Defendant’s convictions and a new trial. View "Blaize v. State" on Justia Law

Police impounded Defendant’s car from a parking lot because he was arrested for driving while suspended, the car’s windshield and bumper were damaged, and the registered owner was not present. When police inventoried the car, they found a handgun inside. Defendant was ultimately convicted of carrying a handgun without a license. The Supreme Court reversed Defendant’s handgun conviction, holding that, as required by Fair v. State, the State failed to prove an established departmental procedure or regulation that authorized the discretionary impound under the community-caretaking function, and therefore, the State failed to prove that the impoundment was reasonable. View "Wilford v. State" on Justia Law

In 2002, Defendant was adjudicated delinquent in Texas for a sex offense. Defendant was required to register in Texas as a sex offender until 2014. In 2006, Indiana amended the Sex Offender Registry Act’s definition of sex offender to include “a person who is required to register as a sex offender in any jurisdiction.” In 2009, Defendant moved to Indiana but did not register as a sex offender. Defendant was charged with failing to register as a sex offender in Indiana. Defendant moved to dismiss the charge, arguing that enforcing the registry requirement would be an ex post violation because his offense occurred before the change to the definition of sex offender took effect. The trial court denied the motion. The Supreme Court affirmed, holding that Defendant has failed to show the amended definition retroactively punished him, and therefore, there was no ex post facto law violation. View "Tyson v. State" on Justia Law

In 1992, Defendant was convicted in Michigan of a sex offense. Michigan and Indiana later enacted laws requiring convicted sex offenders to register with local law enforcement. Pursuant to Michigan’s Sex Offender Registration Act, Defendant was required to register as a sex offender for twenty-five years upon his release from prison in 1999. In 2006, the Indiana General Assembly amended the definition of sex offender in Indiana’s Act to include “a person who is required to register as a sex offender in any jurisdiction.” In 2012, Defendant moved to Indiana, where he was required to register for the remainder of his Michigan registration period. Defendant petitioned for removal from the registry, arguing that enforcing the requirement would be an ex post facto violation as applied to him because, at the time he committed the underlying offense, neither Michigan nor Indiana had adopted Sex Offender Registration Acts. The trial court granted Defendant’s petition. The Supreme Court reversed, holding that the 2006 definitional amendment to the Michigan Act does not impose a punitive burden on Defendant beyond that which Michigan has already imposed, and therefore, there is not ex post facto violation. View "State v. Zerbe" on Justia Law