Justia Criminal Law Opinion Summaries

The Supreme Court vacated Defendant's sentence of consecutive prison terms totaling forty-nine years in connection with his conviction of two counts of child molesting, holding that Defendant did not waive his right to be physically present at sentencing.Following his conviction, Defendant became sick and could not be transported to the courthouse for sentencing. Defendant's original sentencing hearing was continued to a new date, but before the new sentencing date, Defendant was hospitalized for a leg amputation. On the day of the sentencing hearing, the trial court, court reporter, prosecutor, and defense counsel traveled to the hospital and concluded that Defendant waived his right to be present at the hearing. The trial court proceeded to sentence Defendant. The Supreme Court vacated the sentence and remanded for a new sentencing hearing, holding that, under these circumstances, this Court could not condone a sentencing hearing at a hospital. View "Williams v. State" on Justia Law

The Supreme Court dismissed Defendant's appeal of the sentence imposed in connection with his plea of guilty to four theft-related charges, holding that Defendant's written plea agreement with the State, which both he and his attorney signed, unambiguously waived his right to appeal his sentence.In exchange for a more lenient sentence, Defendant agreed to plead guilty to four theft-related charges and waive his right to appeal his conviction and sentence. The trial court accepted Defendant's plea and sentenced him to four years for burglary and thirty months for theft, ordering the sentences to run concurrently. Defendant appealed, but the court of appeals dismissed the appeals with prejudice. The Supreme Court affirmed, holding that this Court could not nullify Defendant's appeal waiver through direct appeal based on the claim that the waiver was not knowing and voluntary, but Defendant could still seek relief through post-conviction proceedings. View "Davis v. State" on Justia Law

The Supreme Court vacated a preliminary injunction granted by the trial court preliminarily enjoining the State from enforcing Senate Bill 1, which broadly prohibits abortion but makes exceptions in three circumstances, holding that Plaintiffs could not show a reasonable likelihood of success on their facial challenge.Plaintiffs, several abortion providers, brought this lawsuit seeking to invalidate Senate Bill 1 on the grounds that the law materially burdened a woman's exercise of her right to "liberty" under Ind. Const. Art. I, 1. The trial court agreed and granted the preliminary injunction. The Supreme Court reversed, holding (1) Plaintiffs had standing to contest the constitutionality of Senate Bill 1; (2) Senate Bill 1 was judicially enforceable; (3) Article 1, Section 1 protects a woman's right to an abortion that the extent that it is necessary to protect her life or to protect her from a serious health risk, but, otherwise, the General Assembly retains legislative discretion in determining the extent to which prohibit abortions; and (4) the record in this case did not support a preliminary injunction. View "Members of the Medical Licensing Bd. v. Planned Parenthood Great Northwest, Hawai'i, Alaska, Indiana, Kentucky, Inc." on Justia Law

The Supreme Court affirmed the decision of the trial court granting summary judgment for Appellant's mental health providers for not preventing his crime of voluntary manslaughter, holding that Defendant was collaterally estopped from relitigating his responsibility.Appellant pleaded guilty but mentally ill to voluntary manslaughter. Thereafter, Appellant sued his mental health providers, arguing that they were legally responsible for his act. The trial court granted summary judgment for Appellees. The court of appeals reversed. The Supreme Court granted transfer, thus vacating the court of appeals' opinion, and affirmed, holding (1) Appellant was estopped from relitigating his legal responsibility under defensive issue preclusion; and (2) Appellees carried their summary judgment burden of establishing that Appellant's damages were not compensable. View "Miller v. Patel, M.D." on Justia Law

The Supreme Court affirmed the judgment of the trial court excluding certain testimony from the jury trial of Defendant's habitual offender status, holding that the trial court did not err by excluding the testimony.The trial court excluded Defendant's testimony to the circumstances of his "most serious crime of conviction," his intent to rehabilitate himself, and his purported innocence of one of his prior, unrelated felonies as irrelevant to the issue of whether Defendant had accumulated the requisite convictions. The Supreme Court affirmed, holding that Defendant's testimony was irrelevant because it did not tend to prove or disprove his convictions, and therefore, Defendant had no constitutional right to present the evidence. The Supreme Court affirmed, holding (1) Defendant's testimony was irrelevant because it did not tend to prove or disprove his convictions; and (2) Defendant had no constitutional right to present irrelevant evidence. View "Harris v. State" on Justia Law

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

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

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

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

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