Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Indiana
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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of "dealing in a look-a-like substance," a level five felony under Ind. Code 35-48-4-4.6, holding that trial court did not err in denying Defendant's motion to suppress.At a casino, Defendant offered to sell a substance to a stranger, who reported the incident. Thereafter, a Gaming Enforcement Agent led Defendant to an interview room and proceeded to pat him down. The trial court admitted the evidence discovered as a result of the pat down. The Supreme Court affirmed, holding (1) the search and seizure proceeded within the bounds of the Fourth Amendment; and (2) therefore, the trial court did not abuse its discretion in admitting evidence obtained as a result. View "Johnson v. State" on Justia Law

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The Supreme Court reversed the order of the trial court denying Defendant's motion to dismiss his habitual offender enhancement, holding that Defendant's constitutional right to a speedy trial was violated by an extraordinary six-plus-year delay.Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual offender enhancement. The court granted the State permission to retry the habitual offender allegation, but it would be nearly six and a half years before Defendant was retried. Before his retrial, Defendant filed a motion to dismiss, alleging a violation of Ind. Crim. R. 4(C) and his constitutional right to a speedy trial. The court denied Defendant's motion to dismiss. After a trial, a jury found that Defendant was a habitual offender. The Supreme Court reversed, holding (1) Defendant was not entitled to discharge under Rule 4(C) because that rule does not apply to the retrial of a habitual offender allegation; but (2) Defendant's constitutional right to a speedy trial was violated, and therefore, Defendant was entitled to relief. View "Watson v. State" on Justia Law

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The Supreme Court expressly overruled the constitutional tests set forth in Richardson v. State, 717 N.E.2d 32 (Ind. 1999), in resolving claims of substantive double jeopardy and adopted an analytical framework that applies the statutory rules of double jeopardy.The Richardson court adopted a comprehensive analytical framework constituting of a statutory elements test and an actual evidence test for deciding all substantive double jeopardy claims under Ind. Const. art. I, 14. Application of the tests, however, proved largely untenable, resulting in a patchwork of conflicting precedent and inconsistent standards. Defendant in this case was convicted of several offenses for leaving the scene of an accident after striking and injuring the victim while driving drunk. The Supreme Court overruled Richardson and adopted a framework that applies when a defendant's single act or transaction implicates multiple criminal statutes. The Court then held that Defendant's multiple convictions violated the statutory rules of substantive double jeopardy. View "Wadle v. State" on Justia Law

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The Supreme Court reversed the judgment of the trial court suppressing blood test results obtained the morning of a vehicle collision, holding that the blood-draw search warrant application satisfied the filing requirement under Ind. Code 35-33-5-2(a).Defendant caused a head-on collision when he drove the wrong way on a freeway. Defendant filed a motion to suppress blood test results obtained the morning of the accident, arguing that Ind. Code 35-33-5-2 and his constitutional rights against unreasonable search and seizure were violated when the arresting state trooper failed properly to file a probable cause affidavit to obtain a blood-test search warrant. The trial court granted the motion, concluding that a copy of the probable cause affidavit was not properly "filed" until a few hours after it had been presented to the warrant-authorizing judge and swiftly executed. The Supreme Court reversed, holding that the blood-draw search warrant application satisfied the filing requirement under section 35-33-5-2(a) because (1) the warrant-authorizing judge certified that the affidavit had been properly filed with her when the search warrant was issued; and (2) even if the affidavit was filed a few hours late it was still valid under Indiana's substantial compliance filing doctrine. View "State v. Ryder" on Justia Law

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The Supreme Court affirmed the judgment of the trial court overruling Defendant's motion to suppress evidence obtained during the search of his vehicle, holding that law enforcement officers do not violate either the state or federal constitution by searching a person's vehicle when the person drives that vehicle up to his house while officers are executing a search warrant for the house that does not address vehicles.In his motion to suppress, Defendant argued that the law enforcement in his case exceeded the scope of the search warrant by searching his vehicle, which was not mentioned in the warrant. The trial court denied the motion. The Supreme Court affirmed, holding (1) the general premises warrant permitting law enforcement's search of Defendant's home also supported law enforcement's search of Defendant's vehicle, and therefore, the search did not violate the Fourth Amendment; and (2) the search of Defendant's vehicle did not violate Ind. Const. art. I, 11 because it was reasonable based on the totality of the circumstances. View "Hardin v. State" on Justia Law

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The Supreme Court reversed the order of the trial court holding Defendant in contempt when Defendant refused to unlock her iPhone for a detective, holding that forcing Defendant to unlock her iPhone would violate her Fifth Amendment right against self-incrimination.The State charged Defendant of several offenses. When Defendant was placed under arrest, law enforcement took her iPhone. Believing it contained incriminating evidence, a detective got a warrant ordering Defendant to unlock her iPhone. When Defendant refused, the trial court held her in contempt. The Supreme Court reversed, holding (1) allowing the State to force Defendant to unlock her iPhone for law enforcement would provide law enforcement with information it did not already know, which the State could use in its prosecution against her; and (2) this result is prohibited by the Fifth Amendment's protection from compelled self-incrimination. View "Seo v. State" on Justia Law

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The Supreme Court reversed the decision of the trial court denying Defendant's request to file a belated notice of appeal of his twelve-year sentence, holding that the general waiver of Defendant's "right to appeal" was insufficiently explicit to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence.Defendant pleaded guilty to Level 4 felony dealing in methamphetamine and was sentenced to the maximum term of twelve years incarceration. Defendant did not timely file a notice of appeal. Defendant later sought permission to file a belated notice of appeal, arguing that he was only recently made aware of his right to appeal his sentence. The trial court denied Defendant's request. The Supreme Court reversed, holding that the general waiver of Defendant's "right to appeal," particularly when contained in the same sentence as an unenforceable waiver of post-conviction relief, was insufficient to establish a knowing and voluntary waiver of Defendant's right to appeal his sentence. View "Johnson v. State" on Justia Law

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The Supreme Court reversed the order of the trial court denying Defendant's motion to suppress evidence seized from his home and his father's barn, holding that the search warrants obtained in this case were invalid because the accompanying affidavits did not provide a substantial basis to support the magistrate's probable cause finding.Law enforcement obtained a warrant to plant a GPS tracking device on Defendant's vehicle. When the device stopped providing location readings, the officers discovered that the tracker was no longer attached to Defendant's car. Thereafter, an officer obtained warrants to search Defendant's home and his father's barn for evidence of "theft" of the GPS device. A magistrate issued both search warrants. During the search, officers found drugs, drug paraphernalia, and a handgun. Defendant moved to suppress the seized evidence, arguing that the initial search warrants were issued without probable cause that evidence of theft of the GPS device would be found in his home or his father's barn. The trial court denied the motion. The Supreme Court reversed, holding that the search warrants were invalid because the affidavits did not establish probable cause that the GPS device was stolen and that the good-faith exception to the exclusionary rule did not apply. View "Heuring v. State" on Justia Law

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The Supreme Court affirmed the judgment of the juvenile court committing fifteen-year-old A.M. to the Department of Correction (DOC), holding that A.M. failed to demonstrate that he received ineffective assistance of counsel under the circumstances of this case.After a true finding of disorderly conduct, A.M. was placed on supervised probation. But due to A.M.'s conduct, the probation department recommended his placement with the DOC. After a disposition modification hearing, the juvenile court committed A.M. to the DOC for an indeterminate period. On appeal, A.M. argued that his attorney rendered ineffective assistance during the modification hearing. At issue in this case was whether the standard for deciding the claim was founded in the Sixth Amendment's right to counsel for a criminal proceeding or in the Fourteenth Amendment's due process clause. The Supreme Court held (1) a due process standard governs a child's claim that he received ineffective assistance in a disposition-modification hearing during his delinquency proceedings; and (2) A.M. received effective assistance of counsel during his modification hearing. View "A.M. v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court terminating Mother's and Father's parental rights to seven children, holding that there was sufficient evidence to support the court's termination decision.After the trial court found the seven children to be children in need of services, Parents were ordered to complete services, and Father was ordered to complete sex-offender treatment. Father, however, never completed sex-offender treatment because Father refused to admit wrongdoing. The trial court subsequently terminated Parents' parental rights. On appeal, Mother and Father argued that the trial court violated Father's Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding that there was no constitutional violation because the court never ordered Father to admit to a crime and that the evidence supported the trial court's factual findings, which in turn supported its legal conclusions. View "M.H. v. Indiana Department of Child Services" on Justia Law