Articles Posted in Supreme Court of Indiana

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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

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The trial court did not err in admitting Defendant’s incriminating statements made in a motel room during the course of a custodial interrogation without an electronic recording of those statements. Defendant was charged with and convicted of several drug crimes. On appeal, Defendant argued that two post-Miranda self-incriminating statements he made to officers in a motel room should not have been admitted into evidence because no electronic recording of the statements was made available at trial, as required by Ind. R. Evid. 617. The Supreme Court disagreed, holding that a motel room, as used by law enforcement in this case to carry out an undercover investigation and to search a suspect incident to his arrest, is not a place of detention as defined by Rule 617. View "Fansler v. State" on Justia Law

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At issue in this case was when public school students are entitled to Miranda warnings at school. B.A., who was thirteen years old, was escorted from a school bus and questioned in a vice-principal’s office in response to a bomb threat on a bathroom wall. Three officers wearing police uniforms hovered over B.A. and encouraged him to confess. B.A. moved to suppress the evidence from his interview, arguing that he was entitled to Miranda warnings because he was under custodial interrogation and officers failed to secure waiver of his Miranda rights under Indiana’s juvenile waiver statute, Ind. Code 31-32-5-1. The juvenile court denied the motion and found B.A. delinquent for committing false reporting and institutional criminal mischief. The Supreme Court reversed B.A.’s delinquency adjudications, holding (1) B.A. was in police custody and under police interrogation when he made the incriminating statements; and (2) therefore, B.A.’s statements should have been suppressed under both Miranda and Indiana’s juvenile waiver statute. View "B.A. v. State" on Justia Law

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Because Defendant’s affirmative actions at trial resulted in a violation of his right to an impartial jury, the invited-error doctrine required that Defendant’s conviction be affirmed. After a second trial, Defendant was found guilty of murder. During trial, defense counsel expressly agreed to the trial court’s constitutionally defective procedure for removing and replacing a juror after deliberations had begun. On appeal, Defendant argued that, despite his acquiescence, the court’s procedure violated his constitutional right to an impartial jury, thus resulting in reversible error. The Supreme Court affirmed, holding (1) there is no reason to exempt structural errors from the invited-error doctrine; and (2) Defendant invited the error in this case as part of a deliberate trial strategy, and therefore, his conviction must be affirmed. View "Durden v. State" on Justia Law

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The Supreme Court affirmed the trial court’s decision to uphold the rulings of magistrates that issued a warrant to conduct a thermal-imaging search of a private residence and a warrant to search the physical premises, holding that probable cause supported both warrants. After conducting an investigation to corroborate an anonymous tip of a potential marijuana grow operation at a private residence, the police received a warrant to conduct a thermal-imaging search of the home. The evidence discovered in the search led the police to request the second warrant to search the premises. The search led to Defendant’s conviction for dealing in marijuana and marijuana possession. On appeal, Defendant argued that both warrants lacked probable cause based on uncorroborated hearsay in the underlying affidavits. The Supreme Court disagreed, holding (1) there was sufficient evidence in the first affidavit to corroborate the tipster’s allegation of criminal activity; and (2) the second affidavit contained sufficient information to establish probable cause under the collective-knowledge doctrine. View "McGrath 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. As grounds for the motion, Defendant argued that the search warrant authorizing the search was unsupported by probable cause under the Fourth Amendment and that its execution violated the search-and-seizure protections of the Fourth Amendment and Ind. Const. art. I, 11. The trial court denied the motion. A jury subsequently found Defendant guilty of of several drug-related offenses. The Supreme Court affirmed, holding (1) under a state constitutional analysis, the police did not act unreasonably under the totality of the circumstances; and (2) under a federal constitutional analysis, the search warrant was supported by probable cause. View "Watkins v. State" on Justia Law