Articles Posted in Supreme Court of Indiana

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The Supreme Court granted transfer in this case to eliminate a residual double jeopardy violation not addressed by the court of appeals, holding that one of Defendant's remaining convictions must be reduced to a lesser included offense to eliminate the violation. Defendant was convicted of possession of cocaine, enhanced to a level four felony; possession of a narcotic drug, enhanced to a level five felony; and unlawful possession of a firearm by a serious violent felon and adjudicated a habitual offender. On appeal, Defendant argued that his conviction for firearm possession and the enhancements applied to the drug-related counts violated double jeopardy principles because they were based on the same evidence - his possession of a single firearm. The court of appeals affirmed Defendant's drug-related convictions but reversed and vacated the conviction and sentence for the firearm possession conviction. The Supreme Court held that because Defendant's two drug-related convictions were enhanced based on the same evidence of his possession of a single firearm, Defendant's conviction on possession of a narcotic drug must be remanded for entry of judgment as a level six felony. View "Springfield v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court granting Defendant's motion to suppress statements he made during an interrogation as inadmissible in his criminal trial, holding that there was substantial, probative evidence that Defendant was in custody at the time of the interrogation. Two police officers interrogated Defendant in a secured area at a police station without providing him with required Miranda warnings. In granting Defendant's motion to suppress, the trial court determined that the environment in which Defendant was interrogated was a "police setting." The Supreme Court affirmed, holding that the totality of the circumstances supported the trial court's conclusion that the interrogation was custodial. View "State v. Ruiz" on Justia Law

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The Supreme Court affirmed Defendant’s convictions, holding that accessing Defendant’s historical cell-site location information (CSLI) was a Fourth Amendment search under Carpenter v. United States, 585 U.S. __ (2018), but even if the CSLI evidence should have been excluded, the error was harmless beyond a reasonable doubt. Defendant was convicted of two counts of robbery with a deadly weapon and two counts of unlawful possession of a firearm by a serious violent felon. On appeal, Defendant argued that the State’s warrantless procurement of his CSLI records violated his rights under the Fourth Amendment of the United States Constitution and Ind. Const. art. I, 11. The Supreme Court affirmed. After Carpenter was decided, the United States Supreme Court vacated the Supreme Court’s decision and remanded the case for reconsideration in light of Carpenter. On remand, the Supreme Court held (1) in light of Carpenter, the State’s access to Defendant’s historical CSLI was a Fourth Amendment search; and (2) the admission of the CSLI evidence was harmless beyond a reasonable doubt. View "Zanders v. State" on Justia Law

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The Supreme Court reversed the judgment of the lower courts denying Appellant’s petition for post-conviction relief on the basis that his attorney provided deficient performance that prejudiced him, holding that counsel rendered ineffective assistance to Appellant by failing to properly advise him about the immigration consequences of a misdemeanor guilty plea. Appellant pleaded guilty to stealing less than twenty dollars of merchandise from Walmart without realizing that his guilty plea made him a deportable felon under federal immigration law. Appellant sought post-conviction relief, alleging ineffective assistance of counsel. The lower courts denied relief. The Supreme Court reversed, holding (1) Appellant’s attorney rendered constitutionally deficient performance as a matter of law by independently marking “N/A” next to the citizenship advisement on the standard advisement of rights from before inquiring into Appellant’s citizenship status; and (2) counsel’s deficient performance prejudiced Appellant. View "Bobadilla v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant’s motion to suppress evidence obtained after Defendant was stopped for speeding, holding that there was reasonable suspicion for a traffic stop under the circumstances. At issue was whether there was reasonable suspicion for the traffic stop where the police officer’s calibrated radar indicated that an oncoming vehicle was speeding and the officer verified the radar speed exceeded the posted speed limit but failed to document the excessive speed. The trial court denied Defendant’s motion to suppress on the basis that the officer’s stop of Defendant was based upon his observation that a traffic infraction was being committed. The Supreme Court affirmed, holding that the traffic stop passed muster under both the United States and Indiana Constitutions. View "Marshall v. State" on Justia Law

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The Supreme Court affirmed the decision of the post-conviction court denying Appellant’s petition for post-conviction relief alleging that his trial and appellate counsel were ineffective, holding that, although counsel made some mistakes, counsel’s performance was not deficient. Appellant was convicted of murdering two children and arson. The convictions were affirmed on appeal. Thereafter, Appellant sought post-conviction relief, alleging multiple instances of ineffective assistance by trial and appellate counsel. The trial court denied the petition. The Supreme Court affirmed, holding (1) counsel’s mistakes did not rise to the level of deficient performance pursuant to Strickland v. Washington, 466 U.S. 668 (1984); and (2) further, Appellant had not demonstrated that there was a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. View "Weisheit v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions of four counts of felony child molesting, holding that the attenuation doctrine can apply under the Indiana Constitution and that Defendant’s statements to law enforcement constituted admissible evidence against him. Defendant moved to suppress evidence obtained from an FBI search and subsequent police interviews, alleging that he had been illegally detained and searched. The trial court suppressed evidence obtained from searching Defendant’s computer and electronic equipment, finding that Defendant’s consent to the search was invalid but denied suppression of Defendant’s statements to law enforcement officers, concluding that they were sufficiently attenuated from the illegal search. The court of appeals reversed Defendant’s convictions, holding that the trial court erred in admitting Defendant’s confessions to the officers, ultimately rejecting the attenuation doctrine for Indiana. The Supreme Court vacated the Court of Appeals opinion and affirmed, holding (1) the Indiana Constitution embraces the attenuation doctrine; and (2) Defendant’s statements to law enforcement were sufficiently attenuated from the illegal search so as to be purged from the original taint and were thus admissible at trial. View "Wright v. State" on Justia Law

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The Supreme Court held that the requirement set forth in Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), that an advisement of rights be given prior to police obtaining consent to a search from a person in custody does not extend to drug recognition exams (DRE). At issue was whether police are required to advise a person in custody of his or her right to consult with counsel before obtaining consent to perform the DRE exam. The Court of Appeals concluded that without a Pirtle warning, evidence obtained through a DRE is inadmissible. The Supreme Court disagreed, holding that an advisement is not necessary before police can obtain a person’s valid consent to a DRE. View "Dycus v. State" on Justia Law

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The Supreme Court reversed the determination of the trial court finding that R.R., a juvenile, violated his probation and adjudicating him a delinquent for auto theft and false informing, holding that the trial court violated R.R.’s right to be present at the fact-finding hearing by holding hearing in R.R.’s absence. On appeal, R.R. argued that juveniles have a due process right to be present at fact-finding hearings on a delinquency charge and that the trial court violated this right by holding the hearing in his absence. The Supreme Court assumed without deciding that juveniles are entitled to be present at fact-finding hearings and held (1) a juvenile can waive his right to be present at a fact-finding hearing but must do so according to the juvenile waiver-of-rights statute; (2) there was no waiver of R.R.’s right to be present, and therefore, the trial court violated that right by holding the fact-finding hearing in R.R.’s absence; and (3) the absurdity doctrine did not apply to this case. View "R.R. v. State" on Justia Law

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The Supreme Court summarily affirmed the parts of the opinion of the court of appeals that addressed and rejected J.R.’s challenge to a pat-down search and remanded to the juvenile court to vacate the delinquency adjudication for carrying a handgun without a license (CHWOL) and affirmed the delinquency adjudication for dangerous possession of a firearm, as all parties agreed that double jeopardy principles precluded J.R.’s dual adjudications. The juvenile court found sixteen-year-old J.R. delinquent for committing acts that would be dangerous possession of a firearm and CHWOL, had they been committed by an adult. On appeal, J.R. argued that a pat-down search violated his constitutional right to be free from unreasonable searches. The court of appeals concluded that the pat-down search was constitutional but that J.R.’s adjudication for CHWOL should be vacated on double jeopardy grounds. The Supreme Court affirmed. View "J.R. v. State" on Justia Law