Justia Civil Rights Opinion Summaries

This case involved a seventeen-and-a-half-year-old who murdered his ten-year-old brother. Defendant confessed to the crime and pleaded guilty to murdering his brother, Conner, while he was babysitting. The trial court judge sentenced Defendant to life without parole. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court did not err in allowing the testimony of a medical doctor who suggested that Defendant had traits of a person with psychopathy; (2) the trial court properly weighed the aggravating and mitigating factors in this case; (3) based on the age of Conner, and the particularly heinous nature of the crime, a sentence of life without parole was appropriate under Indiana Appellate Rule 7(B); and (4) under the facts of this case, the imposition of a life-without-parole sentence on a person under the age of eighteen who has been convicted of murder did not violate either the United States or Indiana Constitution.

Defendant was prosecuted for the death of her two-year-old cousin and later convicted of one count of murder, two counts of neglect of a dependent, one count of battery, and one count of misdemeanor false informing. Defendant was sentenced to life imprisonment without the possibility of parole for murder plus a total of five additional years for the other crimes. Defendant challenged her sentence on appeal. The Supreme Court revised Defendant's sentence, holding (1) the appropriate sentence for this defendant was sixty-five years, the maximum term of years for murder; and (2) the prosecutor committed misconduct in this case, but because Defendant's sentence was revised from life without parole to a term of sixty-five years, no further relief was warranted for Defendant's prosecutorial misconduct claim. Remanded.

Defendant pled guilty to operating a motor vehicle after having his license forfeited for life. On the same day, the trial court placed him on home detention under the supervision of a community-corrections program in January 2010. Defendant appealed, arguing that the introduction of certain hearsay evidence at the hearing revoking his community-corrections placement violated his due process right to confrontation. The Supreme Court affirmed the judgment of the trial court, holding that the hearsay evidence introduced at the hearing was substantially trustworthy, and therefore, Defendant's due process right to confrontation was not violated by the admission of the evidence.

Indiana's motor vehicle statutes provide a carve-out through which individuals whose driving privileges are suspended may still commute, provided the device they use to do so meets certain requirements. One requirement is that the maximum design speed of such a device may not exceed twenty-five miles per hour. Defendant in this case was charged with operating a motor vehicle as a habitual traffic violator. The only evidence admitted at trial as to the above requirement was that Defendant was traveling forty-three miles per hour on a flat, dry surface. The trial court found Defendant guilty as charged and revoked his driving privileges for life. The Supreme Court affirmed, holding (1) the statutory scheme was not unconstitutionally vague; and (2) on the basis of a stipulation that Defendant was traveling forty-three miles per hour, and in the face of no rebuttal evidence, it was impossible to claim that no reasonable fact-finder could find beyond a reasonable doubt that Defendant had a maximum design speed in excess of twenty-five miles per hour.

Appellant pled guilty to operating a vehicle while intoxicated endangering a person. The trial court placed Defendant on home detention under the supervision of a community-corrections program before a 2010 amendment to Ind. Code 35-38-2.6-6 took effect. Appellant appealed, claiming that the trial court erred in not giving him good time credit for the time he spent on home detention pursuant to amended section 35-38-2.6-6. The court of appeals remanded to the trial court to determine Appellant's credit class for good time credit purposes during home detention, to calculate the good time credit to which Appellant was entitled, and to adjust his sentence accordingly. The Supreme Court granted transfer and affirmed the trial court, holding (1) the amendment to section 35-38-2.6-6 applies to those who are placed on home detention on or after its effective date; and (2) Appellant was not eligible for good time credit.

After an attempted escape from prison, Defendant pled guilty to kidnapping an officer, criminal confinement while armed with a deadly weapon and resulting in serious bodily injury, and attempted escape. The trial court an aggregate sentence of forty-seven years with three years suspended. Defendant appealed, arguing that the aggregate sentence was inappropriate in light of the nature of the offense and the character of the offender under Appellate Rule 7(B). The court of appeals concluded Defendant had met his burden of establishing that the sentence was inappropriate and revised the sentence. The Supreme Court affirmed, holding that the trial court's sentence was not inappropriate under Rule 7(B) and there was no abuse of discretion.

This case involved a trial court's discretion in granting a mistrial. Defendant vacillated throughout the trial seeking to proceed pro se and at other times wanting court-appointed counsel. Ultimately, the relationship between Defendant and his counsel reached its low point when later in the trial Defendant testified. Defendant complained to the jury about his counsel's trial strategy, and his response to counsel risked a mistrial. The judge then instructed Defendant to stop speaking and directed the jury to be removed from the courtroom. Before the jury left the courtroom, the judge directed the bailiff to cover Defendant's mouth so he would stop talking. Defendant later completed his direct and cross-examinations without incident. Only after Defendant completed his testimony did defense counsel move for a mistrial. The trial court refused to grant a mistrial. The Supreme Court affirmed, holding that Defendant did not suffer actual harm from the bailiff restraining him, and therefore, the court did not abuse its discretion in denying the motion for mistrial.

After a jury trial, Defendant was convicted of conspiracy to commit burglary and was adjudged to be a habitual offender. Defendant subsequently filed a petition for post-conviction relief, alleging prosecutorial misconduct and ineffective assistance of trial counsel. The trial judge granted Defendant's petition, reversed his conviction, and ordered a new trial. The court of appeals reversed. The Supreme Court granted transfer and affirmed the judgment of the post-conviction court, holding that the post-conviction court did not err in concluding that Defendant was entitled to a new trial because of the ineffective assistance of trial counsel and because of prosecutorial misconduct.

After a trial before a commissioner, Defendant was convicted for misdemeanor criminal trespass after Defendant refused to leave a bank upon the request of the bank's manager and a police officer. Defendant appealed, contending that there was insufficient evidence to support any inference that he lacked a contractual interest in the property upon which he was accused of trespassing. The court of appeals reversed and vacated the conviction. The Supreme Court granted transfer and affirmed Defendant's conviction, holding that there was sufficient evidence from which a reasonable jury could infer that Defendant did not have a contractual interest in the bank's real property.

Defendant Michael Sharp was convicted and sentenced for two counts of child molesting. The court of appeals rejected Sharp's several appellate claims and affirmed the trial court. Seeking transfer, Sharp asserted a single claim, that the court of appeals should have considered his credit restricted felon status when evaluating his request for appellate sentence review. The Supreme Court affirmed, rejecting the rationale applied by the court of appeals but reaching the same outcome regarding the appropriateness of Sharp's sentence, holding (1) appellate sentence review may take into consideration the potential consequences of an offender's status as a credit restricted felon; but (2) Sharp's sentence was appropriate.