Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the trial court denying Defendant's motion arguing that he should receive credit time from the date of his erroneous release through his readmission to the Department of Corrections (DOC), holding that Defendant was entitled to credit time as if he were still incarcerated during the period erroneously spent at liberty.Upon intake to the DOC, Defendant was erroneously awarded 450 days of jail credit. Consequently, Defendant was released from custody with 450 days left on his sentence. The State subsequently requested that Defendant be readmitted to the DOC to serve the time owed on his felony sentence. The trial court ordered that Defendant be returned to the DOC to finish serving his sentence. The Supreme Court reversed and remanded the case, holding that, as long as the defendant bears no active responsibility in his early release, he is entitled to credit while erroneously at liberty as if still incarcerated. View "Temme v. State" on Justia Law

The Supreme Court reversed the order of the trial court suppressing statements made by Defendant during a police interview, holding that the circumstances did not amount to a custodial interrogation.At issue was whether Defendant's freedom of movement was curtailed to a level associated with formal arrest when he had a free-flowing exchange in a detective's personal office. In granting Defendant's motion to suppress the trial court concluded that the circumstances were akin to a custodial interrogation and that the statements were obtained in violation of the Fifth Amendment. The Supreme Court disagreed and reversed the suppression order, holding that the limited curtailment of Defendant's freedom of movement did not amount to a formal arrest. View "State v. Diego" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress the fruits of an inventory search of the company van he was driving, holding that the van's seizure and search were lawful.Defendant was driving his company van when we served off the road, demolished a utility box, then drove to his nearby home. The responding officer found Defendant as he was parking in his front driveway and took him to the hospital for a blood test. Later, other officers conducted an inventory search of the van, which revealed pills in a bag under the driver's seat, and then towed the van as evidence of leaving the scene of an accident. Defendant was charged with several offenses and moved to suppress the pills. The trial court denied the motion to suppress, and a jury convicted Defendant of most of the charges. The Supreme Court affirmed, holding that the search and seizure of Defendant's van fell under recognized exceptions to the warrant requirement of the Fourth Amendment, and therefore, the police officers lawfully discovered the pills. View "Combs v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's request to represent himself during trial, holding that the trial court did not err in denying Defendant's request to self-represent.Defendant was charged with, among other things, murder and felony burglary. Defendant petitioned the trial court to represent himself, but the trial court denied the petition, concluding that Defendant equivocated in his desire to self-represent and that the request was based upon a misapprehended understanding of the law. The Supreme Court affirmed, holding (1) while Defendant's waiver of the right to counsel was knowing and voluntary, his waiver was neither unequivocal nor intelligent; and (2) therefore, the trial court properly denied Defendant's request to represent himself. View "Wright v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendant's motion to suppress evidence seized during the search of his home, holding that a waiver of the "right against search and seizure" clearly informs the defendant that a search may be conducted without reasonable suspicion.When a defendant is processed for home detention, he normally signs an agreement in which he forgoes many of his rights. The agreement typically includes consent to allow community corrections to search the defendant's person or home to ensure compliance with the rules. Defendant in this case argued that the search of his home violated his Fourth Amendment rights because the contract he signed when he was placed on home detention didn't include a waiver of searches without reasonable suspicion. The trial court granted the motion to suppress. The Supreme Court reversed, holding that the contract unambiguously informed Defendant that he waived his right against search and seizure absent reasonable suspicion. View "State v. Ellis" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of attempted murder, holding that the trial court did not err in not allowing Defendant's mother as a witness to stay in the courtroom during Defendant's trial.Defendant was fifteen years old when he was waived into adult criminal court and convicted. Before trial, the State listed Defendant's mother as a potential witness, and at trial, the State requested a separation of witnesses order. The court ordered Defendant's mother to leave the courtroom, and the State never called her to testify. The Supreme Court affirmed, holding (1) a child in adult criminal court may use Ind. R. Evid. 615(c) to establish that a parent is "essential" to the presentation of the defense and is thus excluded from a witness separation order; (2) Defendant did not make the requisite showing under the rule; (3) Defendant waived his argument that a juvenile defendant has a due process right to have a parent present for criminal proceedings; and (4) Defendant's challenges to his sentence were unavailing. View "Harris v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to dismiss the State's habitual-offender allegation and remanded with instructions to vacate Defendant's habitual-offender enhancement, holding Defendant's constitutional right to a speedy trial was violated by a six-plus-year delay.Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual-offender enhancement. More than six years passed before the State retried the habitual-offender allegation. Defendant filed a motion to dismiss, but the trial court denied the motion, eventually finding Defendant to be a habitual offender. The Supreme Court reversed, holding (1) Criminal Rule 4(C) does not apply to a habitual-offender retrial; but (2) Defendant's right to a speedy trial was violated, and therefore, Defendant was entitled to relief. View "Watson v. State" on Justia Law

The Supreme Court vacated K.C.G.'s delinquency adjudication and the modification of his probation based on that adjudication, holding that the juvenile court lacked subject matter jurisdiction.The delinquency at issue alleged that sixteen-year-old K.C.G. committed the offense of dangerous possession of a firearm in violation of Ind. Code 35-47-10-5. The juvenile court adjudicated K.C.G. a delinquent and modified his probation. On appeal, Defendant argued that the plain terms of the dangerous-possession statute showed it could not be a delinquent act. The Supreme Court vacated the delinquency adjudication, holding that because the statute defines the offense solely in terms of a "child" with an unauthorized firearm, the dangerous-possession statute does not apply to adults, and therefore, the State's petition did not allege a jurisdictional prerequisite - that K.C.G.'s conduct was "an act that would be an offense if committed by an adult." View "K.C.G. v. State" on Justia Law

The Supreme Court revised the maximum 138-year sentence imposed on Defendant for crimes he committed as a juvenile, holding that the sentence was inappropriate.In 1991, seventeen-year-old Defendant and two others committed a murder and other crimes. Defendant received a total sentence of 138 years, the maximum possible term-of-years sentence. The Supreme Court affirmed on appeal. In 2016, Defendant filed a petition for post-conviction relief, challenging the propriety of imposing the maximum term-of-years sentence on him for crimes committed as a juvenile. The post-conviction court granted the petition and imposed an aggregate sixty-eight-year sentence. The Supreme Court affirmed the post-conviction court's order granting relief and revised the sentence to eighty-eight years, holding that the 138-year sentence was inappropriate. View "State v. Stidham" on Justia Law

The Supreme Court reduced Defendant's sentence imposed in connection with his conviction for two counts of murder, Class B felony armed robbery, and a Class D felony conspiracy to commit criminal gang activity, holding that Defendant's appellate counsel was ineffective on direct appeal by failing to bring an Appellate Rule 7(B) challenge to the appropriateness of Defendant's sentence.Defendant was sixteen years old when he committed the crimes underlying his convictions. On post-conviction review, Defendant argued that his sentence of 181 years constituted a de facto juvenile life sentence that violated the Eighth Amendment. The post-conviction court denied relief. The Supreme Court revised Defendant's sentence downward to an aggregate 100 years, holding (1) Defendant's original sentence was not unconstitutional because the protections outlined in Miller v. Alabama, 567 U.S. 460 (2012), for juvenile life-without-parole sentences are inapplicable to a term of years sentence; but (2) appellate counsel's failure to challenge the sentence's appropriateness amounted to deficient performance, and Defendant was prejudiced by the failure. In the interest of judicial economy, the Supreme Court conducted a review of the sentence under Appellate Rule 7(B) and revised the sentence downward. View "Wilson v. State" on Justia Law