Justia Criminal Law Opinion Summaries

Defendant was charged with battering J.M., his girlfriend. While she was being treated for her injuries, J.M. told a paramedic and forensic nurse that Defendant was the source of her injuries. J.M. was reported missing shortly after the assault and failed to appear for scheduled depositions. The State later provided notice of intent to introduce J.M.'s statement identifying Defendant as her attacker through the testimony of the paramedic and forensic nurse. The trial court granted the motion. After a bench trial, Defendant was convicted of C-felony battery and A-misdemeanor domestic battery. Defendant appealed, arguing that J.M.’s statements were testimonial hearsay admitted in violation of his confrontation rights. The Supreme Court affirmed, holding that J.M.’s hearsay statements were non-testimonial and, therefore, were properly admitted into evidence. View "Ward v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of Class B felony burglary, among other crimes. The burglary convictions resulted from breaking and entering into an old farmhouse. The Supreme Court reversed the two convictions for burglary as Class B felonies and remanded for the entry of two replacement convictions for burglary as Class C felonies, holding that the jury instruction’s expansion of the statutory definition of a “dwelling” for purposes of Class B felony burglary was misleading and invaded the province of the jury and was therefore erroneous. Remanded for resentencing. View "Keller v. State" on Justia Law

Defendant was lawfully placed under arrest for driving without a valid driver’s license. Before the police officer placed Defendant in his police cruiser, he conducted a pat-down search of Defendant’s clothing to check for weapons. The officer discovered a pill container in Defendant’s pocket, opened the container, and found a single narcotic pill for which Defendant did not have a valid prescription. Defendant was charged with driving without a license and possession of a controlled substance. Defendant moved to suppress the evidence of the pill container’s contents, arguing that the officer’s opening of the pill contained was an unreasonable search. The trial court denied Defendant’s motion to suppress. The Supreme Court affirmed, holding that the opening of the pill container was within the scope of a search incident to a lawful arrest and reasonable under the Indiana Constitution. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of the murder of James Allen and the attempted murder of Gerald Beamon. Defendant appealed, arguing that the trial court erred in admitting Beamon’s testimony that Allen told Beamon he had shot Defendant the day before Allen’s murder. The court of appeals affirmed, concluding that the admission of the hearsay evidence was erroneous but harmless. The Supreme Court granted transfer on this issue, vacating that portion of the opinion below, and affirmed the admission of the hearsay testimony, holding that the statements fell within the hearsay exception of Ind. R. Evid. 804(b)(3), and therefore, the trial court did not err in admitting the challenged testimony on that basis. View "Beasley v. State" on Justia Law

Defendant was a passenger in a vehicle that was stopped for not having a properly displayed license plate. The driver was placed under arrest for driving with a suspended license, and the police requested that Defendant exit the vehicle so an inventory search could be conducted. Upon exiting the vehicle, Defendant informed the police that he had a handgun in his pocket. Defendant was later found guilty of carrying a handgun without a license. Defendant appealed, arguing that the trial court erred in refusing to give his tendered final jury instruction on the defense of necessity. The Supreme Court reversed, holding (1) there was some evidence that warranted giving the defense of necessity instruction; and (2) it was error for the trial court to have refused giving the instruction. View "Hernandez v. State" on Justia Law

The State prosecuted three co-defendants on identical charges in the same trial. The Supreme Court reversed the convictions of two of those three co-defendants and remanded to the trial court with instructions to enter judgments of acquittal. The case involving the third co-defendant, Latoya Lee, was indistinguishable from the cases of her two co-defendants with the exception that she belatedly filed her petition to transfer. The Supreme Court granted Latoya’s petition to transfer and reversed her conviction, holding that there was no reason to treat her differently that her co-defendants, who now stand acquitted. Remanded with instructions to enter a judgment of acquittal. View "Lee v. State" on Justia Law

After a jury trial, Defendant was found guilty of two felony counts of dealing in cocaine. The Court of Appeals affirmed, concluding that a detective’s opinion testimony on witnessing a drug transaction led only to an inference of guilt and was not an opinion of guilt itself in violation of Ind. R. Evid. 704(b). The Supreme Court granted transfer, holding (1) the trial court erred in admitting the detective’s statement, as the statement was an opinion of Defendant’s guilt that violated Rule 704(b); (2) the admission of the guilt opinion testimony, however, was harmless error; and (3) on all other issues, the Court of Appeals is summarily affirmed. View "Williams v. State" on Justia Law