Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of dealing in a look-a-like substance, a Level 5 felony under Ind. Code 35-348-4-4.6, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant offered to sell a substance to a strange at a casino, and the incident was captured by video surveillance. A gaming enforcement agent took Defendant to an interview room, patted him down, and found packaged drugs. Defendant moved to suppress the evidence stemming from the pat-down. The trial court denied the motion and found Defendant guilty. The Supreme Court affirmed, holding that the search and seizure proceeded within the bounds of the Fourth Amendment, and therefore, the trial court did not err in denying Defendant's motion to suppress. View "Johnson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of the murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct and that, under the circumstances, Defendant did not demonstrate that the misconduct probably harmed him.After Defendant was convicted, he filed a motion to set aside the verdict based on juror misconduct, alleging that one juror, L.W., falsely answered the juror questionnaire. The juror wrote "N/A," meaning not applicable, in response to questions about the jurors past criminal history and whether she had been a victim of a crime, when those answers should have been a yes. The trial court denied Defendant's motion to set aside the verdict. The Supreme Court affirmed, holding (1) juror L.W. committed gross misconduct; but (2) despite the gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law

The Supreme Court reversed the decision of the trial court denying Defendant's petition for expungement, holding that because the trial court may have denied the petition on the erroneous belief that Ind. Code 35-38-9-4(b)(3) rendered Defendant ineligible for expungement, the case must be remanded.Defendant pled guilty to Class B felony conspiracy to commit burglary. After Defendant completed all the terms of his probation without any violations and waiting the required three years he petitioned for expungement. The trial court denied the petition without explaining its reasoning. The Supreme Court reversed, holding (1) a trial court may consider facts incident to the conviction when evaluating an expungement petition; and (2) a trial court should first determine whether the conviction is eligible for expungement and then whether it merits expungement; and (3) because the trial court did not articulate its reasons for denying Defendant's petition, the case is remanded with instructions for the court to reconsider its decision consistent with this opinion. View "Allen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of molesting and murdering an eighteen-month-old boy, holding that the trial court did not commit fundamental error by admitting improper character evidence and medical-personnel testimony and that Defendant was not entitled to relief based on his challenged aggravators.During sentencing, the jury found three statutory aggravators beyond a reasonable doubt and recommended life imprisonment without parole. The trial court adopted the recommendation. The Supreme Court affirmed, holding (1) Defendant failed to show that the trial court committed fundamental error by admitting certain testimony; and (2) the State introduced sufficient evidence during sentencing to support the torture and child-molest aggravators. View "Tate v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Appellant's petition for expungement, holding that because the trial court may have denied the petition on the erroneous belief that Ind. Code 35-38-9-4(b)(3) rendered Defendant ineligible for expungement, remand was required.Appellant pled guilty to Class B felony conspiracy to commit burglary. After completing the terms of his probation without any violations and waiting the required three years, Appellant petitioned for expungement under section 35-38-9-4. The trial court denied the petition for expungement without explaining its reasoning. The Supreme Court reversed, holding (1) a trial court may consider facts incident to the conviction when evaluating an expungement petition; and (2) because the trial court did not articulate why it denied Appellant's petition, the case must be remanded with instructions for the court to reconsider its decision consistent with this opinion. View "Allen v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct but that it was not likely that Defendant was harmed by the misconduct.The juror at issue wrote "N/A," meaning not applicable, in response to jury questions on her jury questionnaire regarding her past criminal history and whether she had herself been a victim of a crime. The juror, however, had in fact been charged with a crime and had been the victim of domestic abuse. The court of appeals reversed the convictions, finding that the trial court erred in not finding that the juror's false answers amounted to gross misconduct that probably harmed Defendant. The Supreme Court reversed, holding that, despite the jurors gross misconduct, it was unlikely that Defendant was harmed. View "Loehrlein v. State" on Justia Law