Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Indiana
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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

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The Supreme Court affirmed the post-conviction court's denial of Appellant's petition for post-conviction relief alleging ineffective assistance of counsel, holding that that Appellant's arguments were unpersuasive and largely unsupported by the record. Appellant was convicted of two counts of murder and sentenced to death. Appellant petitioned for post-conviction relief, arguing ineffective assistance of counsel. The post-conviction court denied relief. The Supreme Court affirmed, holding (1) trial counsel was not ineffective; (2) Appellant's guilty plea with open sentencing was knowing, intelligent, and voluntary; (3) trial counsel operated under no conflict of interest, and Appellant's conflict of interest claim falls under the Strickland analysis for prejudice, not the presumption of prejudice standard under Cuyler v. Sullivan., 446 U.S. 335 (1980). View "Gibson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and other crimes and sentencing him to life without parole, holding that each of Defendant's contentions on appeal were without merit. Specifically, the Court held (1) sufficient evidence supported Defendant's conviction for auto theft, and the Court needn't address Defendant's felony-murder challenge because the trial court merged those verdicts with his murder convictions; (2) any error in the trial court's admonishments to the jurors each time they were separated wasn't fundamental; (3) the trial court did not violate Defendant's Confrontation Clause rights by admitting post-crime text messages of Defendant's co-conspirator because the messages weren't testimonial; (4) any error in the decision of the trial court to read a withdrawn accomplice liability instruction was harmless; and (5) the trial court did not manifestly abuse its discretion when it sentenced Defendant to life without parole. View "Cardosi v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction of Class A misdemeanor domestic battery, holding that Defendant did not validly waive his right to a jury trial. In the underlying proceedings Defendant signed two advisement of rights forms. By the time he signed the second form the deadline to request a jury trial had passed. Neither form advised Defendant of the timeline to file a demand for a jury trial and that his failure to file a demand within that period would result in the waiver of his right. Further, the first advisement of rights did not inform Defendant that his demand for a jury trial had to be in writing. The Supreme Court held that Defendant did not validly waive his right to a jury trial. Because the evidence was sufficient to support the conviction, the Court noted that the State was free to retry Defendant. View "Dadouch v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court ordering state police officers to turn over to federal authorities a shipped box containing U.S. currency wrapped in multiple layers of sealed packaging that bore the odor of narcotics, holding that the totality of the circumstances established the requisite probable cause to believe the money was proceeds of drug trafficking. The shipped box in this case displayed hallmarks of parcels containing drugs and drug money. The officer sought and was granted a warrant authorizing a search of the package and seizure of proceeds of drug trafficking. Officers proceeded to open the box, and a canine alerted that the money contained therein, and not just the packaging surrounding it, contained the odor of narcotics. The officers then seized the cash and obtained a court order to turn it over to federal authorities. Appellant, the individual who shipped the parcel, argued on appeal that the seizure exceeded the scope of the warrant. The Supreme Court affirmed, holding (1) all the circumstances supplied a basis for probable cause to believe the cash was proceeds of drug trafficking; and (2) therefore, the seizure was lawful, and the trial court properly made its order transferring the property to the federal government. View "Hodges v. State" on Justia Law

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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