Justia Criminal Law Opinion Summaries

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

The Supreme Court reversed Defendant's convictions for several drug-related offenses, holding that the trial court abused its discretion by admitting evidence obtained during a search of Defendant's home.Officer Cody Scott was investigating a robbery when he detained Defendant for an outstanding warrant for his arrest. The officer asked Defendant if he would escort him inside the house, and Defendant agreed to the request. After Officer Scott observed possible narcotics in the residence he obtained a search warrant, the execution of which revealed various drug paraphernalia. The court of appeals affirmed Defendant's convictions, holding that the trial court did not abuse its discretion by denying Defendant's motion to suppress. The Supreme Court reversed, holding that Defendant's protections under Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), were violated in this case, and therefore, the trial court abused its discretion by admitting evidence obtained during the search. View "McCoy v. State" on Justia Law

The Supreme Court overruled State ex rel. Keaton v. Circuit Court of Rush County, 475 N.E.2d 1146 (Ind. 1985), which held that criminal trial courts do not have inherent authority to require the State to produce complete copies of police reports over the prosecuting attorney's timely work product objection, holding that Trial Rule 26(B)(3) supersedes Keaton.In making its holding in Keaton the Supreme Court cited an undue burden on prosecuting attorneys and the potential for abuse by defense counsel. Noting that the majority of prosecutors across the State regularly produce police reports to defendants while the minority automatically assert the work product privilege over those documents the Supreme Court reconsidered its decision in Keaton. The Court then overruled Keaton, holding (1) the decision in Keaton conflicts with Indiana's liberal discovery rules, including Trial Rule 26(B)(3); and (2) the reasons justifying the Court's decision in Keaton are improper considerations in a work product analysis and unsupported in today's modern age. View "Minges v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of six offenses, including unlawful possession of a firearm by a serious violent felon in violation of Ind. Code 35-50-2-8, holding that none of Defendant's allegations of error required reversal.On appeal, Defendant argued that the trial court erred in giving Preliminary Instruction 18, and that the error was fundamental. The court of appeals agreed and reversed. The Supreme Court granted transfer and affirmed, holding (1) Defendant invited any error that arose from Preliminary Instruction 18, which precluded relief on direct appeal; (2) the traffic stop leading to Defendant's arrest did not violate the Fourth Amendment; and (3) Defendant waived his last allegation of error. View "Miller v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court declining to allow Defendant, who was charged with several counts of child molesting, from deposing the child victim under the recently-enacted Ind. Code 35-40-5-11.5, which restricts the statutory right of criminal defendants accused of sexual offenses against children to depose prosecution witnesses, holding that there was no error.In 2020, the State charged Defendant with several counts of child molesting. Before Defendant sought to depose the child victim section 35-40-5-11.5 took effect. The trial court denied Defendant's ensuing motion to depose the child under the statute. The court of appeals reversed, concluding that the statute impermissibly conflicted with the Indiana Trial Rules governing the conduct of depositions. The Supreme Court granted transfer and affirmed, holding (1) the statute was not being retroactively applied to Defendant; (2) the statute was not a procedural statute that could conflict with the Trial Rules and it did not violate constitutional separation of powers provisions; and (3) the statute did not violate any of Defendant's state or federal constitutional rights. View "Church v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court against the State on the State's delinquency petition that it filed against Anthony Neukam, holding that neither the juvenile court nor the circuit court had jurisdiction in this case.Neukam allegedly molested his young cousin both before and after he was eighteen. When Nuekam was twenty, the State brought charges against him in criminal court. When Neukam was twenty-two, the State filed a delinquency petition in juvenile court for acts Neukam allegedly committed before turning eighteen. Thereafter, the Supreme Court decided that juvenile courts lack jurisdiction over delinquency petitions once the accused is age twenty-one. The State then dismissed the juvenile case and moved to amend the criminal case to add counts of child molesting Neukam allegedly committed before he was eighteen. The trial court denied the motion. The court of appeals affirmed, concluding that courts lack jurisdiction when an individual is alleged to have committed a delinquent act before turning eighteen but is over twenty-one when the State files charges. The Supreme Court granted transfer and affirmed, holding that no court had jurisdiction over the charges arising from arising from Neukam's alleged misconduct before his eighteenth birthday. View "State v. Neukam" on Justia Law

The Supreme Court affirmed Defendant's conviction for level-2 felony burglary while armed with a deadly weapon but reversed his sentence, holding that the length of Defendant's aggregate sentence exceeded the consecutive sentencing cap imposed by Ind. Code 35-50-1-2.A jury found Defendant guilty as charged and sentenced him to consecutive sentences cultivating in an aggregate term of thirty-eight and one-half years. The Supreme Court reversed in part, holding (1) burglary is an ongoing crime that encompasses a defendant's conduct inside the premises, terminating only when the unlawful invasion ends; and (2) the length of Defendant's aggregate sentence exceeded the maximum aggregate sentence permitted by the Sentencing Cap Statute. View "Fix v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to four charges, including operating a vehicle while intoxicated and possession of marijuana, holding that any error was harmless.The trial court sentenced Defendant to a total of six years, with two suspended to probation. On appeal, Defendant argued that the trial court committed fundamental error by incorrectly advising him of his right to allocution. The Supreme Court affirmed, holding that Defendant failed to prove that his sentence would have been different had he not testified and been subject to cross-examination. View "Strack v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of one count of felony child molestation, holding that the trial court denied Defendant's requests for a continuance.An impermissible local rule and an improperly issued protective order prevented Defendant's defense attorney from obtaining a copy of the alleged victim's interview. Further, the trial court denied Defendant's requests for a continuance when the state disclosed extensive new evidence the day before trial in order to investigate the new allegations and reconstruct trial strategy. The Supreme Court reversed, holding that the trial court (1) erred in prohibiting Defendant from obtaining a copy of the interview before trial, but reversal was not required on this basis; and (2) abused its discretion by denying Defendant's continuance request, and the error was prejudicial. View "Ramirez v. State" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant did not receive ineffective assistance of counsel at sentencing, holding that Defendant did not receive ineffective assistance of counsel.Defendant was convicted of murdering his brother when Defendant was seventeen years old. Defendant sought post-conviction relief alleging that he received ineffective assistance of counsel at sentencing. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that counsel's performance fell objectively below professional norms or that he was prejudiced by any of counsel's alleged errors. View "Conley v. State" on Justia Law