Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's denial of Appellant's post-conviction petition for permission to file a belated notice of appeal, holding that the appeal should be allowed to proceed.In 1999, Appellant pleaded guilty to burglary, robbery, rape, and criminal confinement, all felonies. In 2021, Appellant filed a petition for post-conviction relief seeking to file a belated notice of appeal under Rule 2 and claiming that when he signed his guilty plea there was no advisement that he had the right to appeal his sentence and that he did not learn of his ability to appeal until that that year. The trial court denied the petition without holding an evidentiary hearing, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant was not at fault in failing to file a timely notice of appeal and was diligent in pursuing his belated notice of appeal. View "Leshore v. State" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the judgment of the criminal court entering an order in limine excluding from evidence the juvenile court's order in a child in need of services (CHINS) proceedings, holding that the trial court did not abuse its discretion by excluding the CHINS order.The Department of Child Services (DCS) filed a petition alleging that E.H., who was less than fourteen years old, was a CHINS. The juvenile court denied the petition after a fact-finding hearing. After further investigation, the State charged Defendant with Level 5 felony battery resulting in bodily injury to E.H. When Defendant sought to introduce at trial the CHINS order as evidence that someone else likely injured E.H. the State filed a motion to exclude that evidence in limine. The trial court granted the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by excluding the CHINS order under the circumstances of this case. View "Means v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of involuntary manslaughter, holding that the trial court violated Ind. Trial Rule 47(D) by denying defense counsel the opportunity to voir dire prospective jurors directly and that the error was not harmless.As the State acknowledged at oral argument, the parties agreed at the time of this opinion, that the trial court violated Trial Rule 47(D) during voir dire when it prohibited defense counsel from questioning prospective jurors directly. The Supreme Court reversed Defendant's conviction and remanded the case for a new trial, holding (1) the trial court went beyond setting reasonable limits on voir dire; and (2) the error was not harmless. View "Doroszko v. Indiana" on Justia Law

The Supreme Court affirmed Defendant's conviction of the murder of her ten-year-old stepdaughter, S.C., and her sentence of life without parole, holding that the State sufficiently carried its evidentiary burden to disprove the existence of "sudden heat" because of a lack of adequate provocation, accompanied by a sustained cooling-off period.At issue was whether the State failed to satisfy its evidentiary burden in negating the mitigating factor of "sudden heat," the necessary condition to reduce Defendant's conviction to voluntary manslaughter. The Supreme Court affirmed Defendant's conviction and life-without-parole sentence, holding that the State satisfied its evidentiary burden in negating the mitigating factor and voluntary manslaughter requirement of sudden heat. View "Carmack v. State" on Justia Law

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