Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the trial court's order denying Petitioner's motion for bond reduction or conditional pretrial release, holding that the General Assembly's recent codification of Criminal Rule 26 and the adoption of evidence-based practices in the administration of bail enhances, rather than restricts, the discretion entrusted to trial courts when executing bail.Petitioner was charged with the level-two felony offense of aiding, inducing, or causing burglary with a deadly weapon. The trial court set Petitioner's bond at $50,000 cash-only. After she was found eligible for home detention, Petitioner filed a motion for a bond reduction or conditional pretrial release. The court of appeals denied the motion. The Supreme Court affirmed, holding (1) trial courts should consider any factor relevant to the detainee's risk of nonappearance and potential danger to the community, and Indiana's recent bail reforms enhance the courts' discretion; and (2) clear and convincing evidence supported the trial court's bail determination. View "Dewees v. State" on Justia Law

The Supreme Court summarily affirmed the opinion of the court of appeals dismissing in part, affirming in part, and reversing in part the judgment of the trial court in this criminal case but reversed the court of appeals' conclusion that remand for a new sentencing was unnecessary, holding that remand was necessary.Defendant was convicted of several offenses for driving his vehicle while intoxicated with his three young grandchildren in the vehicle. On appeal, Defendant argued that his multiple convictions constituted double jeopardy and that the trial court erred in sentencing. The court of appeals remanded the case in part with instructions. The Supreme Court summarily affirmed with one exception, holding that, given the multiple irregularities in Defendant's sentence, remand for resentencing was appropriate. View "McDonald v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant's motion to dismiss the charges brought against him and finding that Ind. Code 35-45-4-8 violated the state and federal constitutions, holding that the State alleged an offense and that the statute is constitutional.Defendant captured cell phone video of his girlfriend performing oral sex on him and then sent it to another person. Defendant was charged under section 35-45-4-8, which criminalizes the non-consensual distribution of an "intimate image." Defendant filed a motion to dismiss, arguing that the statute was unconstitutional on free speech grounds. The trial court granted the motion, finding the statute unconstitutional. The Supreme Court reversed, holding (1) the State properly charged Defendant with violating section 35-45-4-8; and (2) the statute does not violate either the free interchange clause of the Indiana Constitution or the First Amendment to the United States Constitution. View "State v. Katz" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and conspiracy to commit murder and sentencing her to life without parole for her murder charge and to thirty-five years' imprisonment for her conspiracy to commit murder charge, to be served concurrently, holding that there was no prejudicial error.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's convictions for murder and conspiracy to commit murder; (2) there was sufficient evidence to support the jury's finding that Defendant committed the statutory aggravator of murder-for-hire; (3) if there was any error related to the admission or exclusion of evidence, it was harmless; and (4) Defendant's conspiracy sentence did not warrant Appellate Rule 7(B) revision. View "Hall v. State" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant's counsel was not ineffective during his criminal proceedings, holding that counsel provided constitutionally effective assistance.Defendant, who was fifteen years old at the time, was charged as an adult and convicted of murder as an accomplice with a gang enhancement after his friend shot and killed a toddler while firing on a rival during a gang dispute. Defendant sought post-conviction relief, alleging that his trial counsel provided ineffective assistance. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to demonstrate that his counsel was ineffective. View "Bradbury v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murdering twenty-three-month-old P.H. and neglecting three-year-old R.H., resulting in serious bodily injury, holding that none of the alleged errors on appeal warranted reversal.The jury in this case found two statutory aggravators beyond a reasonable doubt and recommended life imprisonment without the possibility of parole for Defendant's murder conviction. The trial court adopted the jury's recommendation. The Supreme Court affirmed Defendant's convictions and sentences, holding that the trial court (1) did not err in its evidentiary rulings; (2) did not err in giving a supplemental jury instruction; and (3) did not err in sentencing Defendant to life without parole. View "Ramirez v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of involuntary manslaughter as a lesser included offense of voluntary manslaughter, holding that the district court did not err in instructing the jury on involuntary manslaughter.The State charged Defendant with voluntary manslaughter as a Class A felony for the fatal shooting of his wife. During trial, the State formally tendered an instruction on the lesser included offense of involuntary manslaughter based on a battery. The court gave the instruction, and the jury found Defendant guilty of involuntary manslaughter. The Supreme Court affirmed, holding (1) the trial court appropriately instructed the jury on involuntary manslaughter; (2) the State presented sufficient evidence to overcome Defendant's self-defense claim; (3) the trial court did not abuse its discretion by denying Defendant's motion to dismiss for prosecutorial misconduct; and (4) the trial court did not abuse its discretion by treating a handgun as an aggravator. View "Larkin v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress on the grounds that the affidavit supporting the search warrant failed to specify the deputies' "training and experience" in detecting the odor of raw marijuana, holding that the trial court did not err.Defendant was charged with dealing in marijuana and possession of marijuana. Defendant filed a motion to suppress, arguing that the search violated his constitutional rights because the affidavit failed to specify the deputies' training and experience in detecting a specific smell. The trial court denied the motion to suppress. The Supreme Court affirmed, holding, as an issue of first impression, that trained and experienced law enforcement officers who affirm that they detect the odor of raw marijuana based on their training and experience may establish probable cause without providing further details on their qualifications to recognize this specific odor. View "Bunnell v. State" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Appellant's petition for post-conviction relief raising challenges to the effectiveness or his trial and appellate counsel, holding that Appellant's claims failed, and he was not entitled to relief.Appellant was convicted of three counts of murder and three counts of criminal recklessness and was sentenced to death. Appellant later filed a petition for post-conviction relief, alleging several claims of ineffective assistance of trial counsel. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claims that his trial counsel were constitutionally ineffective at all phases of Appellant's trial; (2) appellate counsel were not ineffective for failing to raise fundamental-error challenges on direct appeal concerning certain instructions; and (3) Appellant was not entitled to relief on his freestanding challenges to the post-conviction court's rulings. View "Isom v. State" on Justia Law