Justia Civil Rights Opinion Summaries

Defendant was charged with four misdemeanors after a law enforcement officer stopped her vehicle for “unsafe lane movement,” conducted field sobriety tests on Defendant, which she failed, and discovered marijuana concealed in Defendant’s clothing. Defendant filed a motion to suppress, arguing that the officer did not have reasonable suspicion to justify the stop. The trial court denied Defendant’s motion, concluding that, while a video from the officer’s vehicle did not show Defendant’s vehicle leaving the roadway, it did show Defendant’s vehicle veering onto the white fog line, and to the extent the officer’s testimony conflicted with the video, the testimony was more reliable than the video. The Supreme Court affirmed, holding that, under the totality of the circumstances, the officer’s conduct was reasonable, and the stop was constitutional. View "Robinson v. State" on Justia Law

I.T., who admitted to conduct that would be a Class B felony child molesting if committed by an adult, was ordered by the trial court to undergo therapeutic polygraph examinations. During one of those exams, I.T. admitted to molesting two other children. Based on those statements, the State filed a new delinquency petition. I.T. moved to dismiss the petition, arguing that the Juvenile Mental Health Statute, which bars a child’s statement to a mental health evaluator from being admitted into evidence to prove delinquency, barred the State’s evidence. The trial court granted the motion. The State appealed. The Supreme Court affirmed, holding (1) the State may appeal a juvenile court order that suppresses evidence if doing so terminates the proceeding; and (2) the Statute’s limited immunity prohibits both use and derivative use of a juvenile’s statements to prove delinquency. View "State v. I.T." on Justia Law

A driver hit Britney Meux, who later died from her injuries, and fled the scene. The State charged the alleged driver, Jason Cozmanoff, with thirteen crimes, including one count of reckless homicide. A few weeks later, Meux’s Estate sued Cozmanoff for wrongful death. The Estate then served Cozmanoff with discovery requests. If Cozmanoff were to invoke the Fifth Amendment and refuse to comply with the Estate’s requests, the civil jury could infer he was liable for causing Meux’s death. But if he were to provide discovery responses, the State could use his testimony and responses against him in his criminal trial. Cozmanoff moved to stay the civil case pending the resolution of his criminal prosecution, citing his Fifth Amendment privilege. The trial court granted a limited stay of discovery but ordered him to respond to the plaintiff’s complaint. The Supreme Court affirmed, holding that, under the circumstances, the trial court did not abuse its discretion in ordering a stay. View "Hardiman v. Cozmanoff" on Justia Law

After a jury trial, Defendant was convicted of murder, felony murder, robbery, and unlawful possession of a firearm by a serious violent felon. Defendant was sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed Defendant’s conviction and sentence, holding (1) Ind. Code 35-50-2-9(1) is constitutional and its constitutionality does not require that the weighing of aggravators and mitigators be done beyond a reasonable doubt; (2) the trial court did not commit prejudicial error in its rulings regarding admission of evidence, use of an exhibit, instruction on felony murder, provision of a definition of asportation, and denial of surrebuttal; and (3) Defendant’s life sentence without the possibility of parole was appropriate. View "Inman v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary as a class C felony and theft as a class D felony. The court of appeals affirmed. The Supreme Court granted transfer to address Defendant's argument that the trial court erred by admitting DNA evidence in violation of his Sixth Amendment right to confrontation. The Supreme Court affirmed the judgment of the trial court, holding that the trial court did not err in admitting certain DNA evidence, as the Constitution does not require a laboratory technician involved in the chain of custody of DNA evidence to testify at trial in order to satisfy the demands of a defendant's Sixth Amendment right of confrontation. View "Speers v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and of being a habitual offender. The trial court sentenced Defendant to life in prison. Defendant appealed, arguing that the trial court erred in admitting certain evidence and in giving the jury an erroneous limiting instruction. The Supreme Court affirmed, holding (1) the trial court did not err by admitting certain photographs into evidence; (2) the trial court did not err in allowing the introduction of testimony from a state witness; (3) the trial court did not err in admitting evidence of other crimes; and (4) although the trial court erred in giving a limiting instruction directed to the testimony of a witness, the error was not fundamental. View "Halliburton v. State" on Justia Law

After police officers received information about a drug dealer, the officers approached a vehicle in which Appellant was a passenger, ordered her outside the car, and handcuffed her. While Appellant was being interviewed, another officer began an inventory search of the vehicle and found cocaine. Appellant was charged with two drug-related felonies. Appellant moved to suppress the evidence found during the search of her vehicle and the statements she made to the interviewing officer. The trial court denied the motion except as to the statements Appellant made before she received a Miranda warning. The Supreme Court reversed the trial court's denial of Appellant's motion to suppress, holding (1) the officers did not have probable cause to arrest Appellant or to search her vehicle; and (2) a reasonable person in Appellant's shoes would not have understood the Miranda warning to convey a message that she retained a choice about continuing to talk, and therefore, Appellant's post-Miranda statements were inadmissible. Remanded. View "Kelly v. State" on Justia Law

Defendant, a truck driver, was arrested after a deliberate action conducted by the state police uncovered nearly ninety pounds of cocaine in Defendant's cargo. Defendant requested a speedy trial, but the trial court was unable to bring him to trial within the time limit because of court congestion. Defendant filed a motion for discharge, which the trial court denied. Defendant also unsuccessfully moved to suppress the evidence obtained as a result of the traffic stop. Ultimately, Defendant was convicted of two counts of dealing in cocaine. Defendant appealed. The Supreme Court affirmed the admission of cocaine evidence at Defendant's trial and the denial of his motion for discharge, holding (1) neither the police officers' detentions of Defendant nor the collective police action constituted an unreasonable search or seizure; and (2) the trial court's decision to continue Defendant's trial beyond his seventy-day speedy trial window was not clearly erroneous. View "Austin v. State" on Justia Law

After a jury trial, Defendant was convicted of murder and class B felony possession of a firearm by a serious violent felon (SVF). Defendant appealed, claiming (1) the trial court should have given his tendered jury instruction on self-defense, and (2) the trial court erred by not completely bifurcating the trial on his SVF charge from the trial on his murder charge. The Supreme Court affirmed Defendant's convictions, holding that the trial court did not err (1) in utilizing the existing Indiana Pattern Jury Instruction on self-defense and in refusing to give Defendant's tendered jury instruction; and (2) in partially bifurcating the trial. View "Russell v. State" on Justia Law

Defendant was one of three men that police officers encountered in a self-storage facility and ordered to the ground. After questioning Defendant about the contents of the black bag he was carrying, Defendant admitted it contained marijuana. A subsequent search revealed methamphetamine and drug paraphernalia. The officers then searched Defendant's car, which contained marijuana and equipment for manufacturing methamphetamine. The trial court denied Defendant's motion to suppress his confession and the evidence found in the black bag and in his car. The court subsequently convicted Defendant of several drug-related offenses. The Supreme Court reversed Defendant's conviction, holding that Defendant's confession and the evidence leading to his conviction were fruits of an unlawful detention, as the officers' initial stop of Defendant and the subsequent warrantless search of Defendant's bag did not satisfy the requirements of the Fourth Amendment. Remanded. View "Clark v. State" on Justia Law